ML12362A391

License Amendment Request Regarding Proposed Technical Specifications Changes for Spent Fuel Storage

ML12362A391
Person / Time
Site:	Millstone
Issue date:	12/17/2012
From:	Price J Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
12-678
Download: ML12362A391 (61)

Text

Dominion Nuclear Connecticut, Inc. *.' Dominion 5000 Dominion Boulevard, Glen Allen, VA 23060 Web Address: www.dom.com Proprietary Information - Withhold Under 10 CFR 2.390 December 17, 2012 U.S. Nuclear Regulatory Commission Serial No.12-678 Attention: Document Control Desk NSSL/MAE RO Washington, DC 20555 Docket No. 50-336 License No. DPR-65 DOMINION NUCLEAR CONNECTICUT. INC.

MILLSTONE POWER STATION UNIT 2 LICENSE AMENDMENT REQUEST REGARDING PROPOSED TECHNICAL SPECIFICATIONS CHANGES FOR SPENT FUEL STORAGE Pursuant to 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) requests an amendment, in the form of changes to the Technical Specifications (TS) to Facility Operating License Number DPR-65 for Millstone Power Station Unit 2 (MPS2). The proposed changes will revise TS 1.39 "Storage Pattern," TS 3.9.18, "Spent Fuel Pool -

Storage," TS 3.9.19, "Spent Fuel Pool - Storage Patterns," TS 5.3.1 "Fuel Assemblies," TS 5.6.1, "Criticality," and TS 5.6.3, "Capacity." Conforming changes are being made to Technical Specifications Bases (TSB) 3/4.9.18 and 3/4.9.19. These changes reflect the results and constraints of a new criticality safety analysis for fuel assembly storage in the MPS2 fuel storage racks.

The proposed changes have been reviewed and approved by the Facility Safety Review Committee.

The proposed amendment implements the following conditions associated with fuel storage at MPS2. The changes are being requested to allow removal of Boraflex credit:

• Eliminate reactivity credit for Boraflex panels in current regions A and B of the spent fuel pool.

• Revise allowed storage patterns for fuel in the spent fuel pool to meet Keff requirements under normal and accident conditions.

" Revise alphanumeric designation of spent fuel regions from Regions A, B, and C to Regions 1, 2, 3, and 4 to reflect storage requirements and to clearly distinguish from existing designations.

• Require use of control element assemblies or borated stainless steel poison rodlets for fuel assemblies stored in Region 3.

" Eliminate requirement to use spent fuel rack-cell blocking devices.

Attachment 4 contains information that is being withheld from public disclosure under 10 CFR 2.390. Upon separation from the attachment, this letter is decontrolled.

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Page 2 of 4 Information provided in the attachments to this letter is summarized below:

- Attachment 1 provides Description, Criticality Technical Analysis, Regulatory Analysis and Environmental Analysis of the proposed changes. As discussed in this attachment, the proposed amendment does not involve a significant hazards consideration pursuant to the provisions of 10 CFR 50.92.

- Attachment 2 contains marked-up pages to reflect the proposed changes to the TS.

- Attachment 3 contains marked-up pages to reflect the proposed changes to the TS Bases for information only.

- Attachment 4 contains the criticality safety analysis report with information proprietary to DNC, AREVA NP, and Westinghouse Electric Company, LLC (Proprietary).

- Attachment 5 contains the criticality safety analysis report (Non-Proprietary).

- Attachment 6 contains the AREVA NP affidavit.

- Attachment 7 contains the Westinghouse Electric Company, LLC (Westinghouse)

Application for Withholding Proprietary Information from Public Disclosure CAW 3573 and accompanying affidavit.

- Attachment 8 contains the Dominion Resources Services, Inc. affidavit.

Since Attachment 4 contains information proprietary to AREVA NP, Inc. (AREVA),

Westinghouse, and DNC, it is supported by affidavits signed by the owners of the information. The affidavits set forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390.

Accordingly, it is respectfully requested that the proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390.

DNC requests approval of the proposed amendment by December 31, 2014, which supports planned spent fuel pool management activities to eliminate credit for Boraflex panels in the spent fuel racks. Once approved, the amendment will be implemented by September 1, 2015 (to allow time to load multiple dry storage casks and rearrange fuel in the spent fuel pool).

In accordance with 10 CFR 50.91(b), a copy of this license amendment request is being provided to the State of Connecticut.

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Page 3 of 4 Correspondence with respect to the information proprietary to Westinghouse or the supporting Westinghouse affidavit should reference CAW-12-3573 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.

Should you have any questions in regard to this submittal, please contact Wanda D. Craft at (804) 273-4687.

Sincerely, J. AI ice Vice President- Nuclear Engineering IVICKI

. .V____.

L.HULL Notary Public I

S Commonwealth of Virginia 140542 COT OIMy Commission Expires May 31. 2014..

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by J. Alan Price, who is Vice President - Nuclear Engineering of Dominion Nuclear Connecticut, Inc.

He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this _1._7__day of D4C~e.tir, 2012.

My Commission Expires: Al  ; rijq .

Notary Public Commitments made in this letter: None Attachments:

1. Discussion of Technical Specifications Changes

2. Marked-up Technical Specifications Pages

3. Marked-up Technical Specifications Bases Pages for Information Only

4. Criticality Safety Analysis Report (Proprietary)

5. Criticality Safety Analysis Report (Non-Proprietary)

6. Affidavit of AREVA NP, Inc.

7. Affidavit of Westinghouse Electric company, LLC

8. Affidavit of Dominion Resources Services, Inc.

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Page 4 of 4 cc: U.S. Nuclear Regulatory Commission Region I 2100 Renaissance Blvd Suite 100 King of Prussia, PA 19406-2713 James S. Kim Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08 C2A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station Director Bureau of Air Management Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Attachment 1 Evaluation of Technical Specifications Changes DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 1 of 20 Evaluation of Technical Specifications Changes Table of Contents 1.0 Sum m ary Description ........................................................................................ 3 2.0 Detailed Description of Proposed Technical Specifications Changes ............ 5 2.1 TS 1.39 - Definitions ................................................................................ 5 2.2 TS 3.9.18 - Spent Fuel Pool - Storage .................................................... 5 2.3 TS 3.9.19 - Spent Fuel Pool - Storage Pattern ......................................... 7 2.4 TS 5.3.1 - Fuel Assemblies ....................................................................... 8 2.5 TS 5.6.1 - C riticality ................................................................................. 8 2.6 TS 5.6.3 - Capacity ........................................ 9 3.0 Discussion ....................................................................................................... 9 3.1 Introduction .................................................. ............................................ 9 3.2 Current MPS2 Spent Fuel Configuration .............................................. 10 4.0 Technical Evaluation Sum m ary ............................................................................. 11 4.1 Introduction ........................................................................................... 11 4.2 Spent Fuel Pool Criticality Analysis - General ....................... 11 4.3 Spent Fuel Pool Criticality Analysis - Normal Storage Conditions .......... 12 4.4 Spent Fuel Pool Criticality Analysis - Accident Conditions ............... 13 4.5 Boron Dilution Analysis ........................................................................ 14 4.6 Boraflex Material Monitoring ................................................................... 15 4.7 Decreased Fuel Storage ......................................................................... 15 4.8 Implementation Considerations ........................................................... 15 4.9 Conclusions ............................................................................................. 15

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 2 of 20 5.0 Regulatory Evaluation ....................................................................................... 16 5.1 Applicable Regulatory Requirements and Criteria .............................. 16 5.2 No Significant Hazards Consideration .................................................. 16 5.3 Precedents ................................................................... ...........................;19 5.4 Conclusion .............................................................................................. 20 6.0 Environm ental Considerations ........................................................................ 20 7.0 References ............................................................................................................. 20

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 3 of 20 1.0 Summary Description Dominion Nuclear Connecticut, Inc. (DNC) hereby proposes to amend Operating License DPR-65 by incorporating the enclosed proposed changes into the Technical Specifications (TS) of Millstone Power Station Unit 2 (MPS2). DNC is proposing to change, add, or delete the following Technical Specifications:

S TS 1.39 Storage Pattern S TS 3.9.18 Spent Fuel Pool - Storage o Figure 3.9-1A Minimum Required Fuel Assembly Exposure as a Function of Initial Nominal Planar Average Enrichment to Permit Storage in Region 2, Type 2A o Figure 3.9-1 B Minimum Required Fuel Assembly Exposure as a Function of Initial Nominal Planar Average Enrichment to Permit Storage in Region 2, Type 2B o Figure 3.9-1C Minimum Required Fuel Assembly Exposure as a Function of Initial Nominal Planar Average Enrichment to Permit Storage in Region 3 for Assemblies Containing Borated Stainless Steel Poison Rodlets o Figure 3.9-1 D Minimum Required Fuel Assembly Exposure as a Function of Initial Nominal Planar Average Enrichment to Permit Storage in Region 3 for Assemblies Containing a Control Element Assembly o Figure 3.9-1E Minimum Required Fuel Assembly Exposure as a Function of Initial Nominal Planar Average Enrichment to Permit Storage in Region 4 o Figure 3.9-2 Spent Fuel Pool Arrangement o Figure 3.9-3 Minimum Required Fuel Assembly Exposure as a Function of Initial Nominal Planar Average Enrichment to Permit Storage in Region 3 as Consolidated Fuel o Figure 3.9-4 DELETED 0 TS 3.9.19 Spent Fuel Pool - Storage Pattern 0 TS 5.3.1 Fuel Assemblies 0 TS 5.6.1 Criticality 0 TS 5.6.3 Capacity.

The Bases for TS 3.9.18 and TS 3.9.19 are also being modified to address the proposed changes and are provided for information only. Changes to the TS Bases are controlled in accordance with the TS bases control program (TS 6.22).

The proposed changes to the above TS address the following objectives:

• Updates spent fuel pool regionalization, which encompasses replacing Regions A, B, and C with new Regions 1, 2, 3, and 4

• Designates certain Region 1, 2, and 4 fuel storage locations as Restricted Locations which shall not be used to store fuel assemblies, but may be used to store certain non-standard fuel configurations or components, and non-fuel containing components.

• Removes requirements for cell blocking devices.

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 4 of 20

" Requires that fuel assemblies stored in new Region 3 contain either borated stainless steel poison rodlets or a control element assembly (consolidated fuel assembly boxes are excluded from this requirement).

• Removes all reactivity credit for Boraflex.

The proposed changes will allow MPS2 to remove the reactivity credit for Boraflex in the spent fuel racks. In order to meet the spent fuel pool criticality requirements, the following changes are being proposed:

" Increasing the number of regions in the spent fuel pool to four.

• Selected spent fuel storage rack locations are designated as Restricted Locations in Regions 1, 2, and 4 (Revised TS Figure 3.9-2). Fuel assemblies shall not be stored in these locations. Since Restricted Locations will be controlled administratively, cell blocking devices will no longer be required.

" Region 2 has Type 2A and Type 2B storage locations where Type 2A stores higher reactivity fuel than Type 2B.

" The existing enrichment/burnup curves are replaced with five new enrichment/burnup curves to meet the storage requirements in Regions 2, 3, and 4.

• Fuel assemblies stored in Region 3 must contain either borated stainless steel poison rodlets or a control element assembly (with the exception of consolidated fuel storage boxes).

" Consolidated fuel storage boxes can only be stored in Region 3.

The changes have been reviewed and confirmed to accommodate fuel currently in the spent fuel pool and a potential future fuel design.

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 5 of 20 2.0 Detailed Description of Proposed Technical Specifications Changes Details of the analyses supporting the proposed changes are contained in the criticality safety analysis report as provided in Attachment 4 (Proprietary) and Attachment 5 (Non-Proprietary).

2.1 TS 1.39 - Definitions One definition is being updated to provide additional clarification.

Definition 1.39 - STORAGE PATTERN Definition 1.39 is updated to clarify that a STORAGE PATTERN is a 2x2 storage array (encompassing 4 fuel storage rack locations), in which there is at least one location in which a fuel assembly is not to be stored. This definition is changed to improve clarity and to refer to Regions 1, 2, and 4 to which this definition would now apply.

2.2 TS 3.9.18 - Spent Fuel Pool - Storage Technical Specification 3.9.18 currently has 3 subparts (a), (b) and (c) which specify initial enrichment and burnup requirements for storage of spent fuel in Regions A and C and consolidated fuel storage boxes in Region C. The proposed changes define new fuel pool storage Regions 1, 2, 3, and 4, replace the existing enrichment/burnup curves, revise TS Figure 3.9-2 to account for the new regions, and remove TS Figure 3.9-4 since Region 1 will not use a burnup curve.

The proposed changes follow:

LCO 3.9.18 Limiting Condition of Operation (LCO) 3.9.18(a), (b), and (c) are removed and replaced with new LCO 3.9.18(a), (b), (c), (d), and (e). The new items describe the enrichment/burnup requirements (including Region 3 poison insert requirements) to store fuel assemblies in a given region based on the updated spent fuel pool criticality analysis.

Region 1 does not have burnup requirements. Therefore, the fuel assemblies meeting the TS enrichment requirements can be stored in Region 1. Regions 2, 3, and 4 have enrichment/burnup requirements that must be met to allow storage in these regions.

Current Region C credits optional installation of three borated stainless steel poison rodlet inserts. The proposed Region 3, which is composed of all but two of the current Region C fuel storage racks, requires that each fuel assembly contain either three borated stainless steel poison rodlets or a control element assembly

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 6 of 20 (consolidated fuel storage boxes are excluded from this requirement). A footnote is added to this TS stating that the full-length, reduced-strength control element assemblies and the part-length control element assemblies stored in the MPS2 spent fuel racks cannot be used for reactivity control in Region 3.

The enrichment/burnup requirements, poison insert requirements, and Restricted Locations (described in TS 3.9.18) ensure the following:

• under normal operating conditions Keff will remain < 0.95 with 600 ppm of soluble boron in the spent fuel pool, and will remain < 1.0 with 0 ppm of soluble boron in the spent fuel pool.

• under postulated misloading or drop accidents Keff will remain < 0.95 with 1400 ppm of soluble boron in the spent fuel pool.

The following is a discussion of new and updated figures. The values shown in these figures are taken from the criticality safety analysis report.

TS Figure 3.9-1A TS Figure 3.9-1A is revised. This figure shows the minimum required fuel assembly burnup as a function of initial nominal planar average enrichment to permit storage of fuel assemblies in Region 2 within storage locations designated as Type 2A.

TS Figure 3.9-1B TS Figure 3.9-1B is revised. This figure shows the minimum required fuel assembly burnup as a function of initial nominal planar average enrichment to permit storage of fuel assemblies in Region 2 within storage locations designated as Type 2B. Region 2 Type 2A storage locations can store higher reactivity fuel assemblies than Region 2 Type 2B.

TS Figure 3.9-1C TS Figure 3.9-1C is a new figure. This figure shows the minimum required fuel assembly burnup as a function of initial nominal planar average enrichment to permit storage of fuel assemblies containing borated stainless steel poison rodlets in Region 3.

TS Figure 3.9-1D TS Figure 3.9-1 D is a new figure. This figure shows the minimum required fuel assembly burnup as a function of initial nominal planar average enrichment to permit storage of fuel assemblies containing a control element assembly in Region 3.

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 7 of 20 TS Figure 3.9-1E TS Figure 3.9-1 E is a new figure. This figure shows the minimum required fuel assembly burnup as a function of initial nominal planar average enrichment to permit storage of fuel assemblies in Region 4.

TS Figure 3.9-2 TS Figure 3.9-2 is revised. This figure illustrates the new region definitions and storage patterns of the fuel storage racks. The configuration presented in this figure is based on the criticality safety analysis report.

TS Figure 3.9-3 The Figure 3.9-3 legend and title are revised to conform to the criticality safety analysis report. An editorial change is also made to designate the figure as Figure 3.9-3 (currently designated as 3.9.3).

TS Figure 3.9-4 This figure is deleted because Region 1 does not have an enrichment/burnup curve.

2.3 TS 3.9.19 - Spent Fuel Pool - Storage Pattern TS 3.9.19 title is changed from "Storage Pattern" to "Restricted Locations". TS 3.9.19 currently has two subparts (1) and (2) which specify requirements for fuel assemblies stored in Region B when cell blocking devices are installed as shown in the current TS Figure 3.9-2, or when the blocking devices have been removed. The proposed changes remove requirements for cell blocking devices, but designate that Restricted Locations shall not be used to store fuel assemblies. Regions 1, 2, and 4 contain Restricted Locations in the configuration shown in the revised TS Figure 3.9-2.

The proposed changes are as follows:

The TS title is revised to more clearly describe the updated TS.

LCO 3.9.19 LCO 3.9.19(1) and (2) are replaced with the new LCO which states that fuel assemblies shall not be stored in the Restricted Locations.

The footnotes on this page (Page 3/4 9-26) are removed because the proposed changes will require that Batch B fuel assemblies conform to the same enrichment/burnup and poison insert requirements as all other fuel assemblies stored in the fuel pool. The current TS have analyzed and qualified Batch B assemblies for storage in rack locations containing a cell blocking device. The current analysis does

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 8 of 20 not apply to the proposed change which removes the requirement for cell blocking devices, and does not allow storage of any fuel assembly in a Restricted Location.

Thus, Batch B must meet the storage requirements of all other fuel assemblies in the pool, and the current footnotes no longer apply.

Surveillance Requirements 4.9.19 The existing surveillance requirement, which verifies that LCO 3.9.19 is satisfied prior to removing cell blocking devices, is changed since the new surveillance requires verification that LCO 3.9.19 is satisfied through the use of administrative means to assure that a fuel assembly will not be placed into a Restricted Location.

Maintaining the Restricted Locations free of fuel assemblies arid consolidated fuel storage boxes will ensure that under normal operating conditions Keff will remain <

0.95 with 600 ppm of soluble boron in the spent fuel pool, and will remain < 1.0 with 0 ppm of soluble boron in the spent fuel pool.

2.4 TS 5.3.1 - Fuel Assemblies Desigqn Feature 5.3.1 Design Feature 5.3.1 replaces the phrase "nominal average enrichment" with the phrase "initial nominal planar average enrichment" which provides a more precise definition as it is treated in the criticality safety analysis report.

2.5 TS 5.6.1 - Criticality Design Feature 5.6.1 The following changes were made to Design Feature 5.6.1. These changes are supported with the information provided in the criticality safety analysis report.

• Paragraphs a) and b) - replaces the phrase "nominal average enrichment" with the phrase "initial nominal planar average enrichment."

• Paragraphs c) and d) - deletes Westinghouse Report A.-MP-FE-001 1, Revision 1 which was not used in the criticality safety analysis report. The criticality safety analysis report documents that the reactivity and soluble boron design requirements are met.

" Paragraph e) - replaces discussion of previous Region A enrichment burnup requirements with requirements for Region 1. 'Region 1 requirements include crediting Restricted Locations, specifying a maximum initial nominal planar average enrichment requirement of 4.85 weight percent U-235, and that no burnup credit is taken.

" Paragraph f) - replaces discussion of previous Region B enrichment burnup requirements with requirements for Region 2. Region 2 requirements include

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 9 of 20 the Type 2A and Type 2B storage locations and that each Type has its own enrichment/burnup curve.

• Paragraph g) - replaces discussion of previous Region C enrichment burnup requirements with requirements for Region 3. Region 3 requirements include a requirement that each fuel assembly contain either borated stainless steel poison rodlets or a control element assembly. There are also two enrichment/burnup curves for this region, one for fuel assemblies containing borated stainless steel poison rodlets, and one for fuel assemblies containing a control element assembly.

" Paragraph h) - replaces Region C with Region 3. All other information is the same.

" Paragraph i) - new paragraph which discusses Region 4. Information provided is similar to the other paragraphs, including center to center distance, Restricted Locations, and its enrichment/burnup curve.

2.6 TS 5.6.3 - Capacity Design Feature 5.6.3 Design Feature 5.6.3 updates the number of spent fuel pool storage locations (which includes Restricted Locations) for the proposed Regions 1, 2, 3, and 4.

3.0 Discussion 3.1 Introduction DNC proposes to amend Operating License DPR-65 by incorporating the attached proposed changes into the TS of MPS2. DNC is proposing to change the following Technical Specifications described in Section 1.0 above. The supporting criticality safety analysis report is included as Attachment 4 of this submittal.

The proposed amendment implements the following conditions associated with fuel storage at MPS2:

• Eliminate reactivity credit for Boraflex panels in current regions A and B of the spent fuel pool:

o The proposed change will no longer credit Boraflex as a neutron absorber.

The following changes support removal of Boraflex credit.

• Revise alphanumeric designation of spent fuel regions from A, B, C to 1, 2, 3, 4 to clearly distinguish from existing designations:

o Regions 2, 3, and 4 will have new enrichmentlburnup curves. Regions 2 and 3 will each have 2 enrichment/burnup curves.

o Region 1 will not have an enrichment/burnup curve. Any fuel assembly in the spent fuel pool can be stored in Region 1.

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 10 of 20

" Revise allowed storage patterns for fuel assemblies in the spent fuel pool to meet Keff requirements under normal and accident conditions:

o Certain locations will no longer be allowed to store fuel assemblies (proposed TS Figure 3.9-2). Region 1 will only allow fuel assembly storage in a 2 out of 4 storage pattern, and Regions 2 and 4 will allow a 3 out of 4 storage pattern.

Region 3 can store fuel assemblies in any location.

o Only Region 3 has every storage location available.

o Only Region 3 will be able to store consolidated fuel storage boxes.

" Allow use of control element assemblies as well as borated stainless steel poison rodlets in Region 3:

o Fuel assemblies stored in Region 3 would be required to contain borated stainless steel poison rodlets or a control element assembly.

o Consolidated fuel storage boxes are exempted from containing borated stainless steel poison rodlets or a control element assembly.

" Eliminate requirement to use spent fuel rack cell blocking devices:

o Regions 1, 2, and 4 will have storage rack locations that will not be permitted to store fuel assemblies (proposed TS Figure 3.9-2).

3.2 Current MPS2 Spent Fuel Pool Configuration The MPS2 spent fuel pool currently consists of three regions of spent fuel storage racks, designated Regions A, B and C. TS Figure 3.9-2 provides a schematic of the pool layout. The Region A and B racks contain Boraflex as the active neutron absorber in a flux trap design. The Region C racks have an egg crate design with no fixed neutron absorber. Fuel may be stored in three types of configurations in Region C per current TS. Fuel assemblies stored in Region C may be stored with or without borated stainless steel poison rodlets (for reactivity control), and consolidated fuel storage boxes are also allowed to be stored in Region C. The consolidated fuel storage box has essentially the same dimensional envelope as a fuel assembly.

Forty Region B fuel storage locations contain certain low reactivity fuel assemblies underneath cell blocking devices for added reactivity control.

Soluble boron is currently credited in the spent fuel pool for reactivity control for both normal and accident conditions.

The maximum initial nominal planar average enrichment used is the currently licensed value of 4.85 weight percent U-235.

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 11 of 20 4.0 Technical Evaluation Summary 4.1 Introduction The analyses and results summarized in this section are provided in the criticality safety analysis report. DNC addressed the following issues as the most significant technical considerations for the proposed changes.

Use of the cell blocking devices will no longer be required. Fuel storage loading requirements will continue to be maintained by administrative means. Cell blocking devices are not considered to be a sufficient barrier to preclude a fuel misload accident, as they are not permanent. The consequences of such an accident are the same, whether or not a cell blocker is present. The MPS2 spent fuel pool has been analyzed to accommodate a single misload or drop of the highest enrichment fresh fuel assembly in any region as well as multiple assembly misloads along the boundary between regions.

Since a spent fuel pool soluble boron concentration of 600 ppm is credited for reactivity control under normal conditions, assurance must be provided that a spent fuel pool soluble boron dilution event will not cause spent fuel pool boron concentration to be decreased from the LCO minimum value of > 1720 ppm, to < 600 ppm.

These proposed design changes do not result in any hardware changes to the plant.

The cell blocking devices are already of a removable design and not an integral part of the storage racks. There are no changes in how the borated stainless steel poison rodlets are used in Region 3 of the spent fuel pool, or how control element assemblies are placed and stored in fuel assemblies. There are no changes in how fuel is moved, or the process used to qualify and verify fuel storage in the pool other than the updated enrichment/burnup curves and not placing fuel assemblies in Restricted Locations in the fuel pool.

From an operational perspective, the proposed design changes are transparent.

Spent fuel pool soluble boron concentration requirements will riot change. The proposed changes take a partial reactivity credit for the soluble boron currently in place. The changes in enrichment/burnup values lead to the proposed TS Figures 3.9-1A through 3.9-1 E and the deletion of Figure 3.9-4. However, there are no changes in how fuel is moved, or in any method of how administrative means are used to ensure that fuel is not misloaded.

4.2 Spent Fuel Pool Criticality Analysis - General The criticality safety analysis report to support the proposed changes was performed by DNC.

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 12 of 20 The criticality analysis has been conservatively performed by riot crediting any integral fuel burnable absorbers, which typically exist in fresh fuel. The most reactive fuel design is used for each storage region, and the most reactive spent fuel pool water temperature is considered for each region. A tolerance and uncertainty analysis is also provided.

Fuel assemblies used at MPS2 may include reduced enrichment fuel rods adjacent to guide thimbles and reduced enrichment axial blanket regions. For simplicity, the MPS2 criticality calculations are performed using a single enrichment in all fuel rods that is the highest initial planar average U-235 enrichment of the axial regions in the fuel assembly. This averaged enrichment is designated as the initial nominal planar average enrichment.

4.3 Spent Fuel Pool Criticality Analysis - Normal Storage Conditions Region 1 of the spent fuel storage pool is designed to ensure a Keff< 0.95 with the spent fuel pool filled with water borated to a minimum concentration of 600 ppm for normal conditions. Fresh fuel assemblies stored in this region may have a maximum initial nominal planar average enrichment of 4.85 wt % U-235. This region, which contains Restricted Locations, stores fuel assemblies in a 2 out of 4 configuration for reactivity control, as shown in proposed TS Figure 3.9-2.

Region 2 of the spent fuel storage pool is designed to ensure a Keff < 0.95 with the storage pool filled with water borated to a minimum concentration of 600 ppm for normal conditions. Region 2 contains two types of storage locations, Type 2A (higher reactivity) and Type 2B (lower reactivity), as shown in TS Figure 3.9-2. Fuel assemblies stored in this region must comply with Figure 3.9-1A (Type 2A locations) or Figure 3.9-1 B (Type 2B locations) to be in the acceptable burnup domain. This region, which contains Restricted Locations, stores fuel assemblies in a 3 out of 4 configuration for reactivity control, as shown in proposed TS Figure 3.9-2.

Region 3 of the spent fuel storage pool is designed to ensure a Keff < 0.95 with the storage pool filled with water borated to a minimum concentration of 600 ppm for normal conditions. Fuel assemblies stored in Region 3 must contain either borated stainless steel poison rodlets or a control element assembly, except for the full-length, reduced-strength and the part length control element assemblies existing in the fuel pool racks (see proposed change to TS 3.9.18, including its Basis). Fuel assemblies stored in this region must comply with Figure 3.9-1C (containing rodlets) or Figure 3.9-1D (containing a control element assembly) to be in the acceptable burnup domain. Only Region 3 can store consolidated fuel storage boxes (which do not need rodlets or a control element assembly). However, consolidated fuel storage boxes must comply with Figure 3.9-3 to be in the acceptable burnup domain. This region does not contain Restricted Locations.

Region 4 of the spent fuel storage pool is designed to ensure a Keff < 0.95 with the storage pool filled with water borated to a minimum concentration of 600 ppm for

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 13 of 20 normal conditions. Fuel assemblies stored in this region must comply with Figure 3.9-1E to be in the acceptable burnup domain. This region, which contains Restricted Locations, stores fuel assemblies in a 3 out of 4 configuration for reactivity control, as shown in proposed TS Figure 3.9-2.

Note that there are non-standard fuel configurations and components, and non-fuel containing components present in the spent fuel storage racks. These non-standard fuel configurations and components, and non-fuel containing components may be stored in fuel assembly locations if they are demonstrated to be non-limiting with respect to the fuel assemblies that have been analyzed. The same methodology used for the analysis that established the TS requirements will be employed to evaluate non-standard fuel configurations and components, and non-fuel containing components. These non-standard fuel configurations and components, and non-fuel containing components may also be stored in fuel storage rack locations designated as a Restricted Location following an evaluation utilizing the same analysis methodology employed to establish the requirements of this TS.

The above analyses show that, for all Regions of the SFP, 600 ppm of soluble boron is needed under normal conditions to assure that the spent fuel pool Keff is less than or equal to 0.95 (including biases and uncertainties). Also, the criticality analysis shows that even with 0 ppm of soluble boron, under normal conditions the spent fuel pool Keff is less than 1.00 (including biases and uncertainties).

4.4 Spent Fuel Pool Criticality Analysis - Accident Conditiions The spent fuel pool criticality analysis has analyzed the postulated accident conditions listed below. Although some evaluations in the criticality analysis provided in Attachment 4 are performed with fuel having 5.0 wt % U-235 initial nominal planar average enrichment, the current TS limit of 4.85 wt % is not being changed. Thus, the accident analysis in the criticality safety analysis report bounds the proposed change.

" Misplacement or dropping of a single fresh fuel assembly, with a 5.0 wt % nominal planar average enrichment, into a Region 1, 2, 3, or 4 storage location.

• Temperature reaches boiling conditions which increases reactivity in Regions 3 and 4 of the SFP.

" Dropping of a fuel assembly on top of a fuel storage rack which comes to rest in a horizontal or vertical position.

" Misplacement of a fresh fuel assembly, with a 5.0 wt % nominal planar average enrichment, between Region 3 and the new fuel elevator, with a 5.0 wt % fresh fuel assembly in the new fuel elevator.

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 14 of 20 Incorrect fuel assembly placement in which the boundaries between the different regions of the MPS2 fuel-storage racks are out of alignment in such a way that maximizes the reactivity.

For these accident conditions, credit for soluble boron is acceptable per the double contingency principle to ensure that Keff is < 0.95, including uncertainties and biases.

Based on the criticality safety analysis report, the limiting accident is a misloaded fuel assembly. The total amount of soluble boron required is the 800 ppm to compensate for the reactivity increase from the misloaded fuel assembly, plus 600 ppm for normal conditions, for a total of 1400 ppm.

The current TS requires a minimum concentration of 1720 ppm soluble boron at all times that fuel is in the spent fuel pool.

4.5 Boron Dilution Analysis A soluble boron dilution analysis of potential scenarios which could dilute the boron concentration in the SFP demonstrates that sufficient time is available to detect and mitigate a boron dilution prior to reaching the minimum soluble boron required under normal conditions, thus ensuring that Keff 5 0.95 (including biases and uncertainties).

The existing SFP boron dilution analysis established the current SFP minimum TS 3.9.17 soluble boron limit of 1720 ppm. The existing SFP criticality analysis also requires a minimum of 600 ppm under normal operating conditions in the SFP to ensure that Keff meets the design basis requirement. For accident conditions, the existing analysis credited up to 1400 ppm soluble boron in the criticality analysis. The revised criticality analysis has confirmed that a minimum of 600 ppm of soluble boron is sufficient to maintain Keff < 0.95 under normal conditions and that 1400 ppm of soluble boron is sufficient to maintain Keff < 0.95 for postulated accident conditions.

The potential dilution sources described in the existing analysis are not credible threats to the SFP soluble boron concentration from 1720 ppm to 600 ppm due to either volume or flow rate considerations. The large volume of water required to dilute the SFP, the TS controls on SFP boron concentration, observation during plant operator rounds as well as engineered alarms, would effectively detect a dilution event prior to Keff reaching 0.95. These considerations and mitigation measures remain unchanged for the revised criticality analysis. As discussed in Attachment 4, the 600 ppm and 1400 ppm values for normal and accident conditions, respectively, are retained for this analysis. The existing dilution volumes, flow rates, and event mitigation response times remain unchanged for this analysis. The existing boron dilution analysis conclusions remain applicable and unchanged and the proposed change continues to meet the criticality requirements with the current TS minimum soluble boron.

4.6 Boraflex Material Monitoring

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 15 of 20 Region 1 and 2 spent fuel racks contain Boraflex which will no longer be credited as a neutron absorber. Therefore, the Boraflex monitoring program will be discontinued.

4.7 Decreased Fuel Storage The proposed change decreases the number of fuel assemblies that can be stored in the fuel pool due to its implementation of Restricted Locations (there are a greater number of proposed Restricted Locations than current cell blocker locations). Since the spent fuel pool will be licensed to store fewer assemblies, the current mechanical and seismic analyses, as well as the current design basis heat load analysis, remain bounding.

4.8 Implementation Considerations Following NRC approval of the proposed change, DNC will offload a number of spent fuel assemblies into dry storage to clear adequate fuel storage locations. Up to 7 canisters will be loaded and transferred to the Millstone Power Station Independent Spent Fuel Storage Installation (ISFSI). After this campaign is complete, DNC will rearrange fuel in the spent fuel pool so that each fuel assembly will be in compliance with the new spent fuel pool storage configuration and enrichment/burnup curves.

Given the planning and effort needed to perform these fuel storage campaigns, and the uncertainties with projecting a schedule for these complex evolutions more than two years in advance, DNC will complete this work and fully implement the revised TS by September 1, 2015.

4.9 Conclusions Implementation of the proposed changes is safe and will have no effect on current plant operation. There are no hardware changes made to the plant due to these proposed changes. There are no changes in how fuel is handled, or the process used to qualify and verify fuel storage in the pool.

The cell blocking devices are removable, and can be removed from the spent fuel racks. Fuel storage loading requirements will continue to be maintained by administrative means. Cell blocking devices are not considered to be a sufficient barrier to preclude a fuel misload accident, as they are not permanent. The consequences of such an accident are the same, whether or not a cell blocking device is present. The MPS2 spent fuel pool has been analyzed to accommodate a single misload of the highest enrichment fresh fuel assembly in any region as well as multiple assembly misloads along the boundary between regions.

The spent fuel pool criticality analysis to support the proposed modifications uses standard criticality analysis methods. MPS2 continues to maintain the spent fuel pool soluble boron concentration > 1720 ppm. Potential boron dilution events have been previously reviewed, and the review has shown that it is not credible that the spent

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 16 of 20 fuel pool soluble boron concentration can be reduced from > 1720 ppm to < 600 ppm because there is sufficient time available to detect and mitigate a boron dilution event.

The spent fuel racks were designed from a structural perspective for storage of fuel in all rack locations, and the current design basis heat load analysis already bounds the proposed reduction in fuel storage capacity.

The proposed criticality analysis no longer credits Boraflex for neutron absorption.

Thus, it is no longer necessary to continue the Boraflex monitoring program.

5.0 Regulatory Evaluation 5.1 Applicable Regulatory Requirements and Criteria Appendix A to Title 10 of the Code of FederalRegulations, Part 50 (10 CFR 50),

General Design Criterion (GDC) 62, "Prevention of Criticality in Fuel Storage and Handling," states that "criticality in the fuel storage and handling system shall be prevented by physical systems or processes, preferably by use of geometrically safe configurations." The NRC has established a 5% subcriticality margin (i.e., Keff < 0.95) for nuclear power plant licensees to comply with GDC 62.

10 CFR 50.68, "Criticality Accident Requirements," states in subpart (b)(4) that "if credit is taken for soluble boron, the Keff of the spent fuel storage racks loaded with fuel of the maximum fuel assembly reactivity must not exceed 0.95, at a 95 percent probability, 95 percent confidence level, if flooded with borated water, and the Keff must remain below 1.0 (subcritical), at a 95 percent probability, 95 percent confidence level, if flooded with unborated water."

5.2 No Significant Hazards Consideration DNC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by addressing the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below: I

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

Response: No.

The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change will not affect the physical plant, including the spent fuel pool, spent fuel racks, or fuel handling equipment. While there will be more regions to consider in the spent fuel pool, the process of choosing fuel assembly locations will not change other than the regionalization and burnup curves will be revised. Also, the process of handling fuel assemblies will not

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 17 of 20 change. The Millstone Power Station Unit 2 (MPS2) program for choosing fuel assembly storage locations, and for fuel handling and assuring that the fuel assemblies are placed into correct locations will remain in place. The success of this program in preventing misloading and dropping of a fuel assembly has been historically demonstrated. Thus, the probability of a fuel assembly misloading or a fuel assembly drop will not significantly increase with the proposed change.

Multiple postulated accidents were reviewed for the proposed change which included several fuel misloading scenarios and a fuel assembly drop.

The criticality analysis concluded that the limiting accident is a misloaded fresh fuel assembly. The analysis also concluded that this accident requires an additional 800 ppm of soluble boron. The total amount of soluble boron required is the 800 ppm to compensate for the reactivity increase from the fuel assembly misload, plus 600 ppm for normal conditions, for a total of 1400 ppm, which is the same conclusion as the current analysis. The current technical specifications (TS) require a minimum concentration of 1720 ppm soluble boron at all times that fuel is in the spent fuel pool. The proposed TS will maintain this soluble boron requirement.

A boron dilution accident was reviewed. There are no changes to the plant, plant equipment or operations required by the proposed change. Also, the criticality analysis concluded that the current soluble boron requirement (>

1720 ppm) bounds the consequences associated with the proposed change.

Thus, there is no change to consequences of a boron dilution accident.

In the case of each accident, Keff continues to be less than the licensing limit of 0.95. Thus, it is concluded that the consequences of a previously evaluated accident remains that same.

Since the proposed change reduces the number of fuel assemblies that can be stored in the fuel storage racks, the current seismic/structural and heat load analyses bound the proposed change.

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 change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

There is no change to the physical plant, including the equipment and procedures used to handle fuel (or any heavy load) over fuel storage racks, or how the fuel assemblies are stored in the storage racks. Thus, there are

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 18 of 20 no new accidents created over and above the existing postulated accidents of a fuel misload or a fuel assembly drop onto the racks.

Use of cell blocking devices will no longer be required. The cell blocking devices are removable, and can be removed from the spent fuel racks. Fuel storage loading requirements will continue to be maintained by administrative means. Cell blocking devices are not considered to be a sufficient barrier to preclude a fuel misload accident, as they are not permanent. The consequences of such an accident are the same, whether or not a cell blocker is present. The MPS2 spent fuel pool has been analyzed to accommodate a single misload of the highest enrichment fresh fuel assembly in any region as well as multiple assembly misloads along the boundary between regions. Thus, removing the requirement to use cell blocking devices will not create a new accident over and above the existing postulated accidents of a fuel misload or a fuel assembly drop onto the racks.

Reducing the number of fuel assemblies that can be stored in the fuel storage racks will not create any new or different type of accident.

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

Response: No.

The proposed change does not involve a significant reduction in a margin of safety The licensing requirement for the spent fuel pool is that Keff remain less than or equal to 0.95 under all postulated accident conditions (misloaded or dropped fuel assembly, and boron dilution). These accidents were analyzed for the proposed change, and the Keff < 0.95 requirement is met in all cases.

In addition, the criticality analysis concluded that, under normal conditions, the fuel pool Keff will remain less than 1.0 with 0 ppm boron in the pool.

Since the proposed change reduces the number of fuel assemblies that can be stored in the fuel storage racks, the current seismic/structural and heat load analyses' margin of safety bound the proposed change.

Based on the above information, DNC concludes that the proposed license amendment involves no significant hazards consideration under the criteria set forth in 10 CFR 50.92(c) and, accordingly, a finding of no significant hazards consideration is justified.

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 19 of 20 5.3 Precedents The proposed changes to the MPS2 technical specifications are similar in fundamental aspects to the following proposed changes that have been submitted to reflect results of spent fuel criticality analyses:

1. Kirwin, Thomas P, "Palisades License Amendment Request for Spent Fuel Pool Region I Criticality," Letter to Document Control Desk, NRC, from Acting Site Vice President, January 31, 2011 (ADAMS Accession No. ML110380083).

2. Mahesh L. Chawla of the NRC, "Pallisades Nuclear plant - Issuance of Amendment Re: Spent Fuel Pool Region I Criticality," letter from NRC to Vice President, Operations Entergy Nuclear Operations, Inc., January 27, 2012 (ADAMS Accession No. ML11362A468)

3. Kiley, Micheal, "Turkey Point Units 3 and 4 License Amendment Request No. 207, Fuel Storage Criticality Analysis," Letter to Document Control Desk, NRC, from Acting Site Vice President, August 5, 2010 (ADAMS Accession No. ML10220022)

4. Jason C. Paige, "Turkey Point Nuclear Plant, Units 3 and 4 - Issuance of Amendments Regarding Fuel Criticality Analysis," letter to from NRC to Executive Vice President and Chief Nuclear Officer, Florida Power and Light Company October 31, 2011 (ML11216A057)

The current MPS2 application includes unique aspects that reflect DNC's understanding of NRC staff expectations for spent fuel submittal content and supporting analyses. The submittal content was developed based on insights and discussion between DNC and NRC staff which occurred at two pre-submittal meetings:

1. Summary of February 15, 2012, Pre-Application Meeting with Dominion Nuclear Connecticut, Inc., to discuss a Proposed Millstone Power Station, Unit 2, License Amendment Request Concerning Spent Fuel Pool Criticality Re-Analysis, March 12, 2012 (ML120580362)

2. Forth Coming Pre-Application Meeting with Dominion Nuclear Connecticut, Inc., to Discuss a Proposed Millstone Power Station, Unit 2, License Amendment Request Concerning Spent Fuel Pool Criticality Re-Analysis, June 27, 2012 (ML2178A613) 5.4 Conclusion Based on the considerations discussed above, there is reasonable assurance that (1) the health and safety of the public will not be endangered by the proposed changes, (2) such activities will be conducted in compliance with the Commission's regulations,

Serial No.12-678 Docket No. 50-336 Proposed LAR - Criticality Analysis Attachment 1 Page 20 of 20 and (3) the issuance of the requested license amendments will not be inimical to the common defense and security or to the health and safety of the public.

6.0 Environmental Considerations DNC has reviewed the proposed license amendment for environmental considerations.

The proposed license 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 from an environmental assessment as 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. NRC Interim Staff Guidance DSS-ISG-2010-01, Revision 0, "Staff Guidance Regarding the Nuclear Criticality Safety Analysis for Spent Nuclear Fuel Pools",

9/29/2011.

2. NUREG/CR-6801, "Recommendations for Addressing Axial Burnup in PWR Burnup Credit Analyses", ORNL-IM-2001/273, March 2003.

Serial No.12-678 Docket No. 50-336 Attachment 2 Marked-up Technical Specifications Pages DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

-. ptem*b, r 20, 2001 INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.9 REFUELING OPERATIONS 3/4.9.1 BORON CONCENTRATION ....................................................................... 3/4 9-1 3/4.9.2 IN STRU M EN TATION .................................................................................. 3/4 9-2 3/4.9.3 D E CA Y T IM E ................................................................................................ 3/4 9-3 3/4.9.4 CONTAINMENT PENETRATIONS ........................................................... 3/4 9-4 3/4.9.5 D EL E T E D ..................................................................................................... 3/4 9-5 3/4.9.6 D EL E T E D ..................................................................................................... 3/4 9-6 3/4.9.7 D E L E T E D ...................................................................................................... 3/4 9-7 3/4.9.8 SHUTDOWN COOLING AND COOLANT CIRCULATION .................... 3/4 9-8 H igh Water L evel ........................................................................................... 3/4 9-8 Low Water L evel .......................................................................................... 3/4 9-8b 3/4.9.9 D E L E T E D ...................................................................................................... 3/4 9-9 3/4.9.10 D EL E T E D .................................................................................................... 3/4 9-10 3/4.9.11 WATER LEVEL - REACTOR VESSEL ..................................................... 3/49-11 3/4.9.12 STORAGE POOL WATER LEVEL ............................................................ 3/4 9-12 3/4.9.13 D EL E T E D .................................................................................................... 3/4 9-13 3/4.9.14 D EL E T E D .................................................................................................... 3/4 9-14 3/4.9.15 D E L E T E D .................................................................................................... 3/4 9-16 4-3/4.9.16 SH IELD ED CA SK ...................................................................................... 3/4 9-19 3/4.9.17 SPENT FUEL POOL BORON CONCENTRATION .................................. 3/4 9-21 3/4.9.18 SPENT FUEL POOL - STORAGE ............................................................. 3/4 9-22 3/4.9.19 SPENT FUEL POOL - STORP,AGE PATTEP64 ........................................... 3/4 9-26 3/4.9.20 SPENT FUEL POOL - CONSOLIDATION ...................... 3/4 9-27 3/4.10 SPECIAL TEST EXCEPTIONS [RESTRICTED LOCATIONS 3/4.10.1 SHU TD O W N M A RG IN ............................................................................. 3/4 10-1 3/4.10.2 GROUP HEIGHT AND INSERTION LIMITS ......................................... 3/4 10-2 3/4.10.3 D E L E T E D .................................................................................................... 3/4 10-3 MILLSTONE - UNIT 2 IX Amendment No. 69, 4-04, 409, +4--7, 4-5-3, 4--5-8, 240, 24-5, -249,2-74, 280, 284,

March 16, 2006 DEFINITIONS VENTING 1.35 VENTING is the controlled process of discharging air or gas from a confinement to maintain temperature, pressure, humidity, concentration or other operating condition, in such a manner that replacement air or gas is not provided or required during VENTING. Vent, used in system names, does not imply a VENTING process.

MEMBER(S) OF THE PUBLIC 1.36 MEMBER(S) OF THE PUBLIC shall include all persons who are not occupationally associated with the plant. This category does not include employees of the utility, its contractors or its vendors. Also excluded from this category are persons who enter the site to service equipment or to make deliveries. This category does include persons who use portions of the site for recreational, occupational or other purposes not associated with the plant.

The term "REAL MEMBER OF THE PUBLIC" means an individual who is exposed to existing dose pathways at one particular location.

SITE BOUNDARY 1.37 The SITE BOUNDARY shall be that line beyond which the land is not owned, leased or otherwise controlled by the licensee.

UNRESTRICTED AREA 1.38 An UNRESTRICTED AREA shall be any area at or beyond the SITE BOUNDARY to X1' which access is not controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials or any area within the SITE BOUNDARY used for residential quarters or industrial, commercial institutional and/or recreational purposes.

STORAGE PATTERN a&mini..tra:ive

. .ntr.l. This 4th l..ation will be.. fc-r*d to as the bd dAS L.... CTORAGEF PATTERN fefcr-s to a blockcd location and all adjaeent and diagenal eel! leeations surrounditig Te E)e Ee Ovat OR " r Hr e repe* e r-etI lq" replace with Insert T.1 MILLSTONE - UNIT 2 1-8 Amendment No. 4-04, 44-7, 5-5, 4-72, 29,

Insert T.1 to TS 1.39 1.39 A STORAGE PATTERN designates acceptable fuel assembly storage in a 2 x 2 storage array (4 spent fuel rack storage locations) within Regions 1, 2, and 4 of the spent fuel racks. Each 2 x 2 storage array includes at least one location in which a fuel assembly is not to be stored.

April 1, 00; Garee e LcG ntter dated -2 26 014 REFUELING OPERATIONS SPENT FUEL POOL - STORAGE

/"

LIMITING CONDITION FOR OPE-RATION 3.9.18 The following spent fuel pool storage requirement will be met:

0kt) The combination of initial enriehmcint and burnmup of caeh fuci assembly stored in Region A shall becwithin the accoptabic burnHup dtmin of Figure 3.9 4I; and

/

/

I I I I I I I tnti eamcinwatin at tnttat etnrietiment an u poramiaJm1 starced on Region C shall bo within the accpal bumup domainofigr Replace with Insert T.2 The combination f i*nitifal cnrichmcnt and burnup of 4-11Al n /

tatr-Id int Region C sha!! be within the a...ptabl. bu Iup domain of Figure /

3.9 11B, and berated stainless steel poiso pin arc istal&1ed in the assenibly's eenter guide tube and in two diagontally apposite -guidetubes;

.Inominal planar averageI

> (-e-) The combination of initial Aerichment and burnup of each consolidated fuel storage box stored in Region within the acceptable burnup domain of Figure 3.9-3. w

/

APPLICABILITY: Whenever any fuel assembly or consolidated fuel storage box is stored in the spent fuel pool.

ACTION:

Immediately initiate action to move the non-complying fuel assembly or consolidated fuel storage /

/

box to an acceptable location.

The provisions of specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS Inominal planar averageI /

4.9.18 Prior to storing a fuel assembly or c*solidated fuel storage box in the spent fuel racks, verify by administrative means the initial enrichment and burnup of the fuel assembly or consolidated fuel storage box is in accordance with the acceptable specifications for that Storage Region.

3/4 9-22 Amendment No. 4-09, 44-7, 4-5-3, 4-5-8,

/MILLSTONE - UNIT 2 S 11'7/1 )'7A

• Full-length, reduced-strength control element assemblies and part-length control element assemblies are not to be used in Region 3.

Insert T.2 to TS 3.9.18 (a) Region 1 fuel assemblies have a maximum initial nominal planar average enrichment of 4.85 weight percent of U-235. A fuel rod shall have a maximum enrichment of 5.0 weight percent of U-235. No burnup credit is required.

(b) Region 2 has two types of storage locations:

(1) The combination of initial nominal planar average enrichment and burnup of a fuel assembly stored in Region 2 Type 2A shall be within the acceptable burnup domain of Figure 3.9-1A.

(2) The combination of initial nominal planar average enrichment and burnup of a fuel assembly stored in Region 2 Type 2B shall be within the acceptable burnup domain of Figure 3.9-1 B.

(c) Fuel assemblies stored in Region 3 shall contain either borated stainless steel poison rodlets, or a control element assembly:

(1) The combination of initial nominal planar average enrichment and burnup of a fuel assembly containing borated stainless steel poison rodlets stored in Region 3 shall be within the acceptable burnup domain of Figure 3.9-1C. The borated stainless steel poison rodlets shall be installed in the assembly's center guide tube and in two diagonally opposite guide tubes.

(2) The combination of initial nominal planar average enrichment and burnup of a fuel assembly containing control element assemblies stored in Region 3 shall be within the acceptable burnup domain of Figure 3.9-1 D.

(d) The combination of initial nominal planar average enrichment and burnup of a fuel assembly stored in Region 4 shall be within the acceptable burnup domain of Figure 3.9-1 E.

Appil 1,2003 IReplace with Figure 3.9-lA]

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April 1, 2003.

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1.85 4.85 L-Y INITIAL EN.R.IC.HMENT FIGURE 3.9-11B MIfNIMU EL ASSEMBLY EX Ztjj3FION OF INITIAL T TO PERMIT STORAGE IN REGION C WITH POISON PINS NTi tF MILLSTONE - UNIT 2 3/4 9-23a Amendment No. 4-7-2, 2-7-4,

40 30 0

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'-4 a.L 10 10 o --- 4 1.50 2.00 2.50 3.00 3.50 4.00 4.50 5.00 Fuel Assembly Initial Nominal Planar Average Enrichment, Wt% U-235 Figure 3.9-1 B Minimum Required Fuel Assembly Exposure as a Function of Initial Nominal Planar Average Enrichment to Permit Storage in Region 2, Type 2B MILLSTONE -UNIT 2 3/4 9-23a Amendment No.--72, 2-74,

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........................ 4. 8 5 0 V 1.50 2.00 2.50 3.00 3.50 4.00 4.50 5.00 Fuel Assembly Initial Nominal Planar Average Enrichment, Wt% U-235 Figure 3.9-1 C Minimum Required Fuel Assembly Exposure as a Function of Initial Nominal Planar Average Enrichment to Permit Storage in Region 3 for Assemblies Containing Borated Stainless Steel Poison Rodlets MILLSTONE -UNIT 2 3/4 9-23b Amendment No.

40 0

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2.00 2.50 3.00 3.50 4.00 4.50 5.00 Fuel Assembly Initial Nominal Planar Average Enrichment, Wt% U-235 Figure 3.9-1 D Minimum Required Fuel Assembly Exposure as a Function of Initial Nominal Planar Average Enrichment to Permit Storage in Region 3 for Assemblies Containing a Control Element Assembly MILLSTONE -UNIT 2 3/4 9-23c Amendment No.

50 40 0

30 20 2.

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E I1 1.50 2.00 2.50 3.00 3.50 4.00 4.50 5.00 Fuel Assembly Initial Nominal Planar Average Enrichment, Wt% U-235 Figure 3.9-1E Minimum Required Fuel Assembly Exposure as a Function of Initial Nominal Planar Average Enrichment to Permit Storage in Region 4 MILLSTONE -UNIT 2 3/4 9-23d Amendment No.

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0-1.0 1.5 2.0 2.5 3.0 3.5 4.0 45 5.0 FUEL ASSEMBLY INITIAL ENRICHMENT, WT.% U- 35 FIGURE 43--.3. MINIMUM REQUIRED FUEL ASS BLY EXPOSURE AS A UNCTION OF INITIAL RICHMENT TO PERMIT ORAGE IN REGION G AS 4,

-'",--JMC"TSllKRAW I DI AKlAI AVI V :IF/. -

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6 ACCEPTABLE 5

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A d I I I I /1'.I I I I I I I I I I I I I I I I I 0 -

3.35 3.6 3.85 4.1 4.35 4.6 4.85 INITIAL ENRICHMENT 0 __ ,EMILY FIGURE 3.9-4 MINIMU OSURE AS A FUNCTION MILLSTONE - UNIT 2 3/4 9-25a Amendment No. 4-5-9, 2-74,

April 1,200 REFUELING OPERATIONS 'RESTRICTED LOCATIONS SPENT FUEL POOL - STORAGE PATTEP LIMITING CONDITION FOR OPERATION 3).9.19 Eaeh STORAGE PATTERN afthc Region 3 spent fuci pool faeks shall rcgquirc that-64- A ee! blockfing dcvicc is itistalled in these eel! loeations Thownq in Figurce 3.9 2. The bleekd laeatiat may sterc - Ba-tch B3 fu~le.~~4 underneath the teeli lok; or (2.4 if a eel! blockeing deviee has been refmo edp-all-ells in th0 STOsertT.

H PATTERN, &eeept the location with the r-efiedMIbleekitng d-,it ffust be ;vaeant of stored fuciea. mbi APPLICABILITY: Fuel in the spent fuel poo* 41" ACTION: Welete Replceiwith Insert TA4 Take immediate action to comply with either 3.9.19(i.* - (2)

The provisions of specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.19 Vcrify that ;.9.19 is satisfid prior-t cl-egl blockting dcv~icc replace with Insert T.5I A Restricted n* Location may contain non-standard fuel configurations or icomponents, or is empty.

A Batch B fucel assembly r-fcrs to any *the Batch B fucie asseffices which were pat4 e the first Millstone 2 corce.

This

, LC: is not appli:abl. u"ring the initial installation of Batch B fucl assemblies in the

.eli blckcr leeations.

MILLSTONE - UNIT 2 3/4 9-26 Amendment No. 44-7, 3, 4-548, 4-7-2, 274,

Insert T.4 to TS 3.9.19 Fuel assemblies shall not be stored in a spent fuel pool rack Restricted Location (shown in Figure 3.9-2).

Insert T.5 to TS 4.9.19 Prior to storing a fuel assembly in the spent fuel racks, verify by administrative means that it will not be placed in a Restricted Location (as shown in Figure 3.9-2).

DESIGN FEATURES 5.3 REACTOR CORE FUEL ASSEMBLIES initial nominal planar 5.3.1 The reactor core shallr n 217 fuel assemblies with each fuel assembly containing 176 rods. Reload fbe similar in physical design to the initial core loading and shall have a maximum average enrichment of 4.85 weight percent of U-235. A fuel rod shall have a -

Maximu enrichment of 5.0 weight percent of U-235.

initial CONTROL ELEMENT ASSEMBLIES 5.3.2 The reactor core shall contain 73 control element assemblies. The control element assemblies shall be designed and maintained in accordance with the design provisions contained in Section 3.0 of the FSAR with allowance for normal degradation pursuant to the applicable Surveillance Requirements.

5.4 DELETED MILLSTONE - UNIT 2 5-4 Amendment No. , 4-4-9, 446, 2-04, 24-6, 2--0, 2-7,4, 280, 29g-,

DESIGN FEATURES 5.5 DELETED 5.6 FUEL STORAGE CRITICALITY 5.6.1 a) The new fuel (dry) storage racks are desig and shall be maintained with s ficient center to center distance between assemblies tnsure a Keff _< .95. The maximum ie fflinal average fuel assembly enrichment to besed in these racks is 4.85 weight percent U-235. The maximu uel rod enrichment to bered in these racks is 5.0 weight percent of U-235.

b) The spent fuel ge racks are designed and shall be maintained with fuel assemblies having a maximum ntief4n average enrichment of 4.85 weight percent U-235. The maximum fuel rod enrichment to. be stored in these racks is 5.0 weight percent U-23 5.

c) The spent fuel storage racks are designed and shall be maintained with Keff < 1.00 if fully flooded with unborated water, which includes an allowance for uncertainties derefibed i Westifighetts Report A N4P FE; 00 11, Revisiafi I, "Mi litatie Untit 2 Specnt-He4-P riiealti+

Analysis with Soluble Boroan Crodit."

d) The spent fuel storage racks are designed and shall be maintained with Keff*< .95 V fully flooded with water borated to 600 ppm, which includes an allowance for uncertainties 49 d...r.ib.d in Westinghouse ReportA . .P FE 00.11, Revision 1, "Miltane Unit 2 pent Fuel Pool Gr.itiali' Ana lys, with Soluble Boron.-. dit." Replace with Ierl T.7 c1 Rogion A of the spent fi..l storage p. l is d.ign.d and shall bHi mintainded witha nomfinal 9 in-Ph cc-ntcr. tEo cntcr. distanc bet",co traooatiorn. Fuel -assefbliesstar-ed in this region mist cmpl4.with ... Figur- ;.9 4ito nu..that r the design burnup has been sustained.

f) Region B4 of the spent fuel storage -peal is designed and shall be maintatincd with -a nanminal 9.8 inch eenter-to eenter- distancc betvwccf ster-age leeatiens. Reogin B eentains both bleeked and en blocked star-age laeations, shown in Figurc 3'.9 -2.Feel ha i g a maimumf notminal cnrifihment of 1.85 weight perccnt W235, mfay be stored in un blocked locmatons. Fuel star-ed in blockced ieeatians ffust be Batch B fucl asseffblies.

g) Region C=of the spent fuel stafage pool is designed an;;d sha~llb anandwt 9.0 ineh ccntcr-to ccntcr- distanec bctwcct star-age laeations. Fuel assefmblies s~rdinti must comfply with Figer-s 3;.9 6a or 3.9 lb to efnsurc that the design burno up3has bccn.R sustained.

Additionally, fuoel asscmfblies uttilizing Figur-e ;.9 lb rcgquir-e that borated ~tafinles steel Pobo pin arc:-ntal..d in the fuel assembly's c:nter guid. tube and in two d .iagonall, .p..it. g*uid tuc.Thc poo pi ' arc selid 0.87 inceh 0.9. bor-atcd stainless steel, with a boroen eonttont of 2 weight pcrccnt-4 boronR.

h) Region C of thc spent fade steragct pool is designed to pcrmfit ftoage of eeftsolidated fucel. The eententq of the eefisalideAtd fuol steragc baoxc to be saor-d in thbg region rmust comfply with F-tifur 3.9 3ýto enstir- that the design burnuitp has been sustained.

MILLSTONE - UNIT 2 Amendment No. 30, -8,-4-09,4--7,1446, 44-, 172, 482, 24-4, 270, 2-74,

Insert T.7 to TS 5.6.1 e) Region 1 of the spent fuel storage pool is designed and shall be maintained with a nominal 9.8 inch center to center distance between storage locations. Region 1 contains the Restricted Locations, shown in Figure 3.9-2. Fuel having an initial nominal planar average enrichment of 4.85 weight percent U-235 may be stored in available locations. No burnup credit is required.

f) Region 2 of the spent fuel storage pool is designed and shall be maintained with a nominal 9.8 inch center to center distance between storage locations. Region 2 contains the Restricted Locations as well as Type 2A and Type 2B storage locations, shown in Figure 3.9-2. Fuel assemblies stored in this region must comply with Figure 3.9-lA or Figure 3.9-11B to be in the acceptable burnup domain. Fuel assemblies utilizing Figure 3.9-1A must be stored in the Region 2 Type 2A storage locations, and fuel assemblies utilizing Figure 3.9-1 B must be stored in the Region 2 Type 2B storage locations.

g) Region 3 of the spent fuel storage pool is designed and shall be maintained with a nominal 9.0 inch center to center distance between storage locations. Fuel assemblies stored in this region must comply with Figure 3.9-1C or Figure 3.9-1D to be in the acceptable burnup domain. Additionally, fuel assemblies utilizing Figure 3.9-1C require that borated stainless steel poison rodlets are installed in the fuel assembly's center guide tube and in two diagonally opposite guide tubes. The poison rodlets are solid 0.87 inch O.D. borated stainless steel, with a boron content of 2.0 weight percent boron. Finally, fuel assemblies utilizing Figure 3.9-1 D require that a control element assembly be installed in the fuel assembly (except for the full-length, reduced-strength control element assemblies and the part-length control element assemblies).

h) Region 3 of the spent fuel storage pool is designed to permit storage of consolidated fuel. The contents of the consolidated fuel storage boxes to be stored in this region must comply with Figure 3.9-3 to ensure that the design burnup has been sustained i) Region 4 of the spent fuel storage pool is designed and shall be maintained with a nominal 9.0 inch center to center distance between storage locations. Region 4 contains the Restricted Locations, shown in Figure 3.9-2. Fuel assemblies stored in this region must comply with Figure 3.9-1 E to be in the acceptable burnup domain.

DESIGN FEATURES DRAINAGE 5.6.2 The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 22'6".

CAPACITY 1 " I I 1 Il I 5.6.3 The spent fuel storage poo.,e *LLIL*ILL*

M te EB HO ffiffe E RH sterage ae ens n e an I ster-affe epý_AfHHRq- : D R --L-Q.PAR n AR-1

'u'~rnus~ I'~'N1TI~fl2 ir Cý&rý I IC'MTV'fl T'~~ fl v'r'1I ~'T I ~'It~ '~r"rncr'~ unrv'n'~

The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than 160 storage locations in Region 1,224 storage locations in Region 2, 822 storage locations in Region 3, and 1410 storage locations in Region 4 for a total of 1346 storage locations.

MILLSTONE - UNIT 2 5-5a Amendment No. 30, 5-, 4-09, 4-t-7, 446, 4-5-, 4-72, 4,

Serial No.12-678 Docket No. 50-336 Attachment 3 Marked-up Technical Specifications Bases Pages for Information Only DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT

IFOR INFORMATION ONLY April A 1, 2003, REFUELING OPERATIONS The lirmta ndescribed by Figures 3.9 !a, 3.9 1b, and 3.9 3 ensure that the reactivity of fuel assemblies d consolidated fuel storage boxes; introduced into the Region G spent fuel racks, are conservatively within the assumptions of the safety analysis. N 3-A-p be byFigre

.9 estie teA he -eatim-ofthe fuiel assemfblies, ORuee it hr st t asurptions of the 3/4.9.19 SPENT FUEL POOL - STORAGE PATTERN The limitations of this specification ensure that the reactivity condition of the Region storage racks and spent fuel pool Keff will remain less than or equal to 0.95.

11,2, and4

+h nc elt tWIeeKng Wevtees in the 4ht lee Mtauo E)1 me Hegion H~ 3tbrae faeks are desig' BeEl to pr-event iniadve~ent plaeement anid/or- storage in the bi1 kedLleations. Th e blocked loceAtion rean mpty, or-a Bateh B fuel assemfbly mfay be stor-ed in the bloeeked location, to maintftain r-eactivity controal fcr-fuel asseffbly storage in any adaetieftson. RegionH B (nont cell bioeker leeations) is designed fcr-the stor-age of nie", as-em~bqie in-;4 the spent fuiel pool0-, and fo-r-fuel assemblies which have not sus+taifed suffleient burnuip to be stored in Region A or 1-giafi G.

This L6 is ntie applicable during thc initial installeatin of Batch B fus-el afblieS inl the cell blocker loateians of Region B. This is acceptable beeattse only Batch -B fuel assemfblies will be moived during the in1ititl insftallation of Baftch B futel assemblies under +he Regioni-Be1 bleekers. Bateh B fuiel assemblies are qualified fcar storage in any spent fuiel pool ster-age rack location, hence a futel mblosiading event which eauses a r-eactivity eeonsequenee is not cr-edible.

This &eception is valid only dur-itg the inkitia ins~allation of B3atch B fuel assemfblies ini the cell blocker 18eaFUI A-SO E POOL -

-- "lReplace with Insert T.6 3/4.9.20 SPENT FUEL POOL - CONSOLIDATION The limitations of these specifications ensure that the decay heat rates and radioactive inventory of the candidate fuel assemblies for consolidation are conservatively within the assumptions of the safety analysis.

MILLSTONE - UNIT 2 B 3/4 9-4 Amendment No. 4--7, 4--3, 4-5-8, --72, 2-74,

Insert T.6 to TS Bases 3/4.9.19 Fuel storage rack locations designated as Restricted Locations in Figure 3.9-2 shall not be used to store fuel assemblies (Regions 1, 2, and 4). Consolidated fuel storage boxes shall only be stored in Region 3 where there are no Restricted Locations.

There are non-standard fuel configurations and components, and non-fuel containing components present in the fuel storage racks. These non-standard fuel configurations and components, and non-fuel containing components may be stored in fuel assembly locations if they are demonstrated to be non-limiting with respect to the fuel assemblies that have been analyzed. The same methodology used for the analysis that established the Technical Specification requirements will be employed to evaluate non-standard fuel configurations and components, and non-fuel containing components. These non-standard fuel configurations and components, and non-fuel containing components may also be stored in fuel storage rack locations designated as a Restricted Location following an evaluation utilizing the same analysis methodology employed to establish the requirements of this Technical Specification.

Insert T.8 to TS Basis 3/4.9.18.

In addition, the requirement that Region 3 fuel assemblies contain borated stainless steel poison rodlets or a control element assembly ensures that the reactivity of fuel assemblies is conservatively within the assumptions of the safety analysis. Note that the full-length, reduced-strength control element assemblies used in Cycles 1 through 6 (control element assemblies with serial numbers 66 through 73, inclusive) and the part-length control element assemblies used in Cycle 1 (control element assemblies with identifier letters A through H, inclusive) do not satisfy this requirement, and thus are not to be used in Region 3.

Serial No.12-678 Docket No. 50-336 Attachment 7 Affidavit of Westinghouse Electric Company, LLC DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

(Westinghouse Nuclear Services Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 720-0754 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 Proj letter: CMIL--12-9 CAW-12-3573 November 29, 2012 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

"Dominion Spent Fuel Pool Criticality Analysis - Westinghouse Proprietary Information" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-12-3573 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Dominion Nuclear Connecticut, Inc.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW-12-3573, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.

Very truly yours, i/James A. Gresham, Manager Regulatory Compliance Enclosures

CAW-12-3573 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER:

Before me, the undersigned authority, personally appeared James A. Gresham, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

1 James A. Gresham, Manager Regulatory Compliance Sworn to and subscribed before me this 29th day of November 2012 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Anne M. Stegman, Notary Public Unity Twp., Westmoreland County my Commission Expires Aug. 7, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES

2 CAW-12-3573 (1) I am Manager, Regulatory Compliance, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) 1 have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3 CAW-12-3573 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-12-3573 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in "Dominion Spent Fuel Pool Criticality Analysis - Westinghouse Proprietary Information" (Proprietary), for submittal to the Commission, being transmitted by Dominion Nuclear Connecticut, Inc. letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with spent fuel pool rack information for criticality analysis and may be used only for that purpose.

This information is part of that which will enable Westinghouse: to:

(a) Perform spent fuel pool analysis

5 CAW-12-3573 Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of the information to its customers for the purpose of spent fuel pool analysis.

(b) Westinghouse can sell support and defense of spent fuel pool analysis.

(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

Serial No.12-678 Docket No. 50-336 Attachment 8 Affidavit of Dominion Resources Services, Inc.

DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

Serial No.12-678 Docket No. 50-336 10 CFR § 2.390 APPLICATION FOR WITHHOLDING AND AFFIDAVIT OF J. ALAN PRICE I, J. Alan Price, Vice President - Nuclear Engineering, state that:

1. I am authorized to execute this affidavit on behalf of Dominion Resources Services, Inc. (DRS).

2. Dominion Nuclear Connecticut, Inc. (DNC), an affiliate company of DRS, is submitting a License Amendment Request, "Dominion Nuclear Connecticut, Inc.

Millstone Power Station Unit 2 License Amendment Request Regarding Proposed Technical Specifications Changes for Spent Fuel Storage" dated December 17, 2012, for NRC review and approval. The License Amendment Request updates the Millstone Unit 2 spent fuel pool storage configuration and associated constraints and will allow elimination of reactivity credit for Boraflex panels in the spent fuel pool. This License Amendment Request contains unique, first time aspects of methodologies that DRS has utilized to analyze burnup credits for the updated spent fuel pool criticality analyses.

The Proprietary Version of the License Amendment Request contains proprietary commercial information that should be held in confidence by the NRC pursuant to the policy reflected in 10 CFR §§ 2.390(a)(4) because:

a. This information is being held in confidence by both DRS and DNC.

b. This information is of a type that is held in confidence by DRS and DNC, and there is a rational basis for doing so because the information contains sensitive commercial information to DRS regarding methods used to analyze burnup credits as it relates to spent fuel pool criticality analyses.

c. This information is being transmitted to the NRC in confidence.

d. This information is not available in public sources and could not be gathered readily from other publicly available information.

e. Public disclosure of this information would create substantial harm to DRS by disclosing the unique, first time aspects of these methodologies to other parties not involved in the development of the criticality analyses. The methodologies were developed by DRS to analyze burnup credits for updated spent fuel pool criticality analyses in order to meet recent NRC Interim Staff Guidance (NRC Document DSS-ISG-2010-01, Revision 0, "Staff Guidance Regarding the Nuclear Criticality Safety Analysis for Spent Nuclear Fuel Pools," 9/29/2011) and NUREG/CR-7108 and

Serial No.12-678 Docket No. 50-336 NUREG/CR-7109. DRS has expended significant engineering resources in the development of this information. Therefore, disclosure of this information to other parties would permit them to use the information without the expenditure of similar resources, thus giving them a competitive advantage.

3. Accordingly, DRS requests that the designated document be withheld from public disclosure pursuant to the policy reflected in 10 CFR §§ 2.390(a)(4).

DominionRe urces Services Inc.

J. Alq Pr VicePreis ent - Nuclear Engineering VICKI L.HULL STATE OF _ _ I I__A Notary Public Commonwealth of Virginia COUNTY OF My Commission Expires May 31, 2014 Subscribed and sworn to me, a Notary Public, in and for the County and State above named, this "- day ofbec.r*-y,,er ,2012.

Ick ý-Qi\

My Commission Expires: 5-3 L (