L-2013-075, License Amendment Request 226 & 10 CFR 50.12 Exemption Request - Optimized ZIRLO Fuel Rod Cladding

License Amendment Request 226 & 10 CFR 50.12 Exemption Request - Optimized ZIRLO Fuel Rod Cladding

ML13100A131
Person / Time
Site:	Turkey Point
Issue date:	03/22/2013
From:	Kiley M Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2013-075
Download: ML13100A131 (25)

Text

0FPL.

March 22, 2013 L-2013-075 10 CFR 50.90 10 CFR 50.12 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, D.C. 20555-0001 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 License Amendment Request 226 & 10 CFR 50.12 Exemption Request Optimized ZIRLO Fuel Rod Cladding

References:

1. WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOTM,,'

July 2006.

In accordance with the provisions of 10 CFR 50.90, Florida Power & Light Company (FPL) requests that Appendix A of Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Units 3 and 4 be amended to allow the use of Optimized ZIRLOTm as an approved fuel rod cladding. This change is consistent with the U.S. Nuclear Regulatory Commission (NRC) allowed use of Optimized Z'RLOTM fuel cladding material as documented in the Safety Evaluation included in Addendum 1-A to Westinghouse topical report WCAP-126 10-P-A &

CENPD-404-P-A, "Optimized ZIRLOTm" (Reference 1).

To support this change to allow the use of Optimized ZIRLOTM in accordance with 10 CFR 50.12, FPL is also requesting an exemption from certain requirements of 10 CFR 50.46, "Acceptance Criteria for Emergency Core Cooling Systems for Light Water Nuclear Power Reactors," and Appendix K to 10 CFR 50, "ECCS Evaluation Models." This exemption request relates solely to the specific types of cladding material specified in these regulations for use in light water reactors. As written, the regulations presume use of either Zircaloy or ZIRLO fuel rod cladding. The exemption is required since Optimized ZIRLOTm has slightly different composition than Zircaloy or standard ZIRLO.

The Enclosure to this letter contains a description of the proposed changes with supporting technical justifications, a no significant hazards determination, an environmental consideration, and an exemption request.

The proposed changes have been evaluated in accordance with 10 CFR 50.91 (a)(1), using the criteria provided in 10 CFR 50.92(c) and FPL has determined that the proposed changes do not involve a significant hazards consideration.

FPL has determined that the proposed amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and no significant increase in individual or cumulative occupational radiation exposure. Therefore, AX,

Turkey Point Nuclear Plant L-2013-075 Docket Nos. 50-250 and 50-251 Page 2 of 2 FPL has concluded that the proposed amendments meet the criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment need not be prepared in connection with issuance of the amendments.

The proposed changes have been evaluated in accordance with the criteria provided in 10 CFR 50.12(a) and FPL has determined that the proposed changes satisfy the requirements for an exemption from the requirements of 10 CFR 50.46 and Appendix K to 10 CFR Part 50 for Turkey Point Units 3 and 4.

This letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments.

If you have any questions or require additional information, please contact Mr. Robert J.

Tomonto, Licensing Manager, at (305) 246-7327.

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

Executed on March.-4k, 2013.

Very truly yours, Michael Kiley Site Vice President Turkey Point Nuclear Plant Enclosure cc:

USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant Ms. Cindy Becker, Florida Department of Health

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 License Amendment Request 226 & 10 CFR 50.12 Exemption Request Optimized ZIRLO Fuel Rod Cladding L-2013-075 Enclosure Page 1 of 14 Turkey Point Units 3 and 4 LICENSE AMENDMENT REQUEST 226 & EXEMPTION REQUEST -

OPTIMIZED ZIRLO FUEL ROD CLADDING Enclosure 23 pages

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 License Amendment Request 226 & 10 CFR 50.12 Exemption Request Optimized ZIRLO Fuel Rod Cladding TABLE OF CONTENTS LICENSE AMENDMENT REQUEST 226 & EXEMPTION REQUEST - OPTIMIZED ZIRLO FUEL ROD CLADDING L-2013-075 Enclosure Page 2 of 14 1.0 2.0 3.0 4.0 5.0 6.0 7.0 SECTION TITLE Cover Sheet Table of Contents Purpose and Scope Background Information Description of Proposed Changes List of Commitments No Significant Hazards Determination Environmental Consideration References PAGE 1

2 3

3 4

10 10 12 13 TOTAL PAGES 6

ATTACHMENT I

Request for Exemption from the Provisions of 10 CFR 50.46 & 10 CFR Part 50 Appendix K to Allow Use of Optimized ZIRLOTM Fuel Cladding Technical Specification Markups 2

3

Turkey Point Nuclear Plant L-2013-075 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request 226 & 10 CFR 50.12 Exemption Request Page 3 of 14 Optimized ZIRLO Fuel Rod Cladding

1.0 Purpose and Scope

Florida Power & Light Company (FPL) proposes to revise the Turkey Point (PTN) Units 3 and 4 licensing basis by amending Appendix A of Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Units 3 and 4 to incorporate the enclosed TS revisions. The proposed change will revise the TS to allow the use of Optimized ZIRLOTM fuel rod cladding material.

Additionally, pursuant to 10 CFR 50.12 Florida Power & Light requests an exemption from the provisions of 10 CFR 50.46, "Acceptance Criteria for Emergency Core Cooling Systems for Light-Water Nuclear Power Reactors," and Appendix K to 10 CFR Part 50, "ECCS Evaluation Models" to allow the use of Optimized ZIRLOTM fuel rod cladding in future core reload applications for Turkey Point Units 3 and 4. This exemption request is included as Attachment 1.

2.0 Background Information Optimized ZIRLOTM was developed to meet the needs of longer operating cycles with increased fuel discharge burnup and fuel duty. Optimized ZIRLO~m fuel cladding is different from standard ZIRLOTM in two respects: 1) the tin content is lower; and 2) the microstructure is different. This difference in tin content and microstructure leads to differences in some material properties. Optimized ZIRLOT provides a reduced corrosion rate while maintaining the benefits of mechanical strength and resistance to accelerated corrosion from abnormal chemistry conditions. In addition, fuel rod internal pressure (resulting from the increased fuel duty, use of integral fuel burnable absorbers, and corrosion/temperature feedback effects) have become more limiting with respect to fuel rod design criteria. Reducing the associated corrosion buildup and thus minimizing temperature feedback effects provides additional margin to the fuel rod internal pressure design criterion.

Technical Specification (TS) changes for Turkey Point Units 3 and 4 are required to allow the use of Optimized ZIRLOTM fuel rod cladding for core reload applications.

Furthermore, as part of the industry focus to minimize the potential for fuel failure, several licensees have received staff approval to use Optimized ZIRLOTM.

Dominion has received approval at North Anna Power Station, Units 1 and 2, Surry Power Station, Units 1 and 2, (Reference 8-10) and most recently, Millstone Power Station, Unit 3 (Reference 11). Indiana Michigan Power Company has also received approval at D.C. Cook Nuclear Plant, Unit 1 and 2 (References 12-13).

Turkey Point Nuclear Plant L-2013-075 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request 226 & 10 CFR 50.12 Exemption Request Page 4 of 14 Optimized ZIRLO Fuel Rod Cladding 3.0 Description of Proposed Changes The proposed Turkey Point License Amendment Request (LAR) change will revise the Technical Specifications (TS) to allow the use of Optimized ZIRLOTM fuel rod cladding material. The current acceptable fuel rod cladding material is identified in TS 5.3.1, Reactor Core, Fuel Assemblies. The proposed change would revise TS 5.3.1 to add Optimized ZIRLOTM to the approved fuel rod cladding materials and TS 6.9.1.7 to add Westinghouse Electric Company LLC (Westinghouse) topical report WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A "Optimized ZIRLOTm,' to the analytical methods used to determine the core operating limits previously reviewed and approved by the Nuclear Regulatory Commission (NRC).

A specific description of each change is provided below. In addition, TS mark-ups are provided in Attachment 2 of this document.

3.1 Technical Specification 5.3.1, Reactor Core, Fuel Assemblies Current TS The core shall contain 157 fuel assemblies with each fuel assembly containing 204 fuel rods clad with Zircaloy-4 or ZIRLOtn, except that replacement of fuel rods by filler rods consisting of stainless steel, or by vacant rod positions, may be made in fuel assemblies if justified by cycle-specific reload analysis using NRC-approved methodology. The reactor core contains approximately 71 metric tons of uranium in the form of natural or slightly enriched uranium dioxide pellets.

Each fuel rod shall have a nominal active fuel length of 144 inches. Should more than 30 individual rods in the core, or 10 fuel rods in any fuel assembly, be replaced per refueling, a Special Report discussing the rod replacements shall be submitted to the Commission within 30 days after cycle startup.

Proposed TS The core shall contain 157 fuel assemblies with each fuel assembly containing 204 fuel rods clad with Zircaloy-4, ZIRLO, or Optimized ZIRLOTM, except that replacement of fuel rods by filler rods consisting of stainless steel, or by vacant rod positions, may be made in fuel assemblies if justified by cycle-specific reload analysis using NRC-approved methodology. The reactor core contains approximately 71 metric tons of uranium in the form of natural or slightly enriched uranium dioxide pellets. Each fuel rod shall have a nominal active fuel length of 144 inches. Should more than 30 individual rods in the core, or 10 fuel rods in any fuel assembly, be replaced per refueling, a Special Report discussing the rod replacements shall be submitted to the Commission within 30 days after cycle startup.

Turkey Point Nuclear Plant L-2013-075 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request 226 & 10 CFR 50.12 Exemption Request Page 5 of 14 Optimized ZIRLO Fuel Rod Cladding 3.2 Technical Specification 6.9.1.7, Core Operating Limits Report Current TS Core operating limits shall be established and documented in the CORE OPERATING LIMITS REPORT (COLR) before each reload...

The analytical methods used to determine FQ(Z), FAlH and the K(Z) curve shall be those previously reviewed and approved by the NRC in:

1. WCAP-9220-P-A, Rev. 1, "Westinghouse ECCS Evaluation Model-1981 Version," February 1982.

7. WCAP-12610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report," S. L. Davidson and T. L. Ryan, April 1995.

Proposed TS Core operating limits shall be established and documented in the CORE OPERATING LIMITS REPORT (COLR) before each reload...

The analytical methods used to determine FQ(Z), FalH and the K(Z) curve shall be those previously reviewed and approved by the NRC in:

1. WCAP-9220-P-A, Rev. 1, "Westinghouse ECCS Evaluation Model-1981 Version," February 1982.

7. WCAP-12610-P-A. "VANTAGE+ Fuel Assembly Reference Core Report," S. L. Davidson and T. L. Ryan, April 1995.

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

3.3 Technical Evaluation Optimized ZIRLOTM is described in Westinghouse topical report WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A "Optimized ZIRLOTM," dated July 2006 (Reference 1).

The NRC staff's Safety Evaluation (SE) for Optimized ZIRLOTM dated June 10, 2005, requires that licensees referencing Addendum 1-A to implement Optimized ZIRLO comply with the ten conditions and limitations listed within the SE (Reference 2).

The ten conditions and limitations laid out in the NRC's SE for WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A are listed below. FPL will comply with these conditions and limitations as follows:

1.

Until rulemaking to 10 CFR Part 50 addressing Optimized ZIRLOTM has been completed, implementation of Optimized ZIRLOTM fuel clad

Turkey Point Nuclear Plant L-2013-075 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request 226 & 10 CFR 50.12 Exemption Request Page 6 of 14 Optimized ZIRLO Fuel Rod Cladding requires an exemption from 10 CFR 50.46 and 10 CFR Part 50 Appendix K.

RESPONSE: A request for the required exemption from 10 CFR 50.46 and 10 CFR Part 50 Appendix K is provided as a separate attachment to this submittal.

2.

The fuel rod burnup limit for this approval remains at currently established limits: 62 GWd/MTU for Westinghouse fuel designs and 60 GWd/MTU for CE fuel designs.

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

3.

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

RESPONSE: The maximum fuel rod waterside corrosion for fuel using Optimized ZIRLOTM fuel rod cladding will be confirmed to be less than the specified proprietary limits for all locations of the fuel rod.

Evaluations are performed to confirm that the appropriate corrosion limits are satisfied as part of the normal reload design process.

4.

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

RESPONSE: The fuel analysis of Optimized ZIRLOTM fuel rod cladding will continue to meet all conditions associated with approved methods.

For Turkey Point Units 3 and 4, this is a current requirement, and confirmation of these conditions is required as part of the normal reload design process.

5.

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

Turkey Point Nuclear Plant L-2013-075 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request 226 & 10 CFR 50.12 Exemption Request Page 7 of 14 Optimized ZIRLO Fuel Rod Cladding RESPONSE: The application of ZIRLO and Optimized ZIRLOTM in approved methodologies will be made consistent with the approach accepted in WCAP-126 10-P-A & CENPD-404-P-A, Addendum 1-A "Optimized ZIRLOTm," July 2006. For Turkey Point Units 3 and 4, this is a current requirement, and confirmation of these conditions is required as part of the normal reload design process.

6.

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

a.

Optimized ZIRLOTM LTA (Lead Test Assembly) data from Byron, Calvert Cliffs, Catawba, and Millstone.

i.

Visual ii.

Oxidation of fuel rods iii.

Profilometry iv.

Fuel rod length

v.

Fuel assembly length

b.

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

Confirmation of the approved models' applicability up through the projected end of cycle burnup for the Optimized ZIRLOTM fuel rods must be completed prior to their initial batch loading and prior to the startup of subsequent cycles. For example, prior to the first batch application of Optimized ZIRLOTM, sufficient LTA data may only be available to confirm the models' applicability up through 45 GWd/MTU. In this example, the licensee would need to confirm the models up through the end of the initial cycle. Subsequently, the licensee would need to confirm the models, based upon the latest LTA data, prior to re-inserting the Optimized ZIRLO'm fuel rods in future cycles. Based upon the LTA schedule, it is expected that this issue may only be applicable to the first few batch implementations, since sufficient LTA data up through the burnup limit should be available within a few years.

RESPONSE: Westinghouse has provided the NRC with information related to test data and models in the letters referenced in Section 7 of this enclosure (References 3-7 & 15).

Turkey Point Nuclear Plant L-2013-075 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request 226 & 10 CFR 50.12 Exemption Request Page 8 of 14 Optimized ZIRLO Fuel Rod Cladding LTA measured data and favorable results from visual examinations of once, twice, and thrice-burned LTAs confirm, up to the fuel rod burnup limit, that the current fuel performance models are applicable for Optimized ZIRLOTM clad fuel rods. Through transmittal of the information contained in the above mentioned letters, Westinghouse has fulfilled its obligation to provide additional data from the Optimized ZIRLOTM LTA programs to the NRC. FPL will continue to use the currently approved fuel performance models for all Optimized ZIRLOTm fuel assemblies Lp to the approved fuel burnup.

7.

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

a.

Vogtle growth and creep data summary reports.

b.

Using the standard ZIRLO and Optimized ZIRLOTM database including the most recent Vogtle data, confirm applicability with currently approved fuel performance models (e.g., level of conservatism in Westinghouse rod pressure analysis, measured vs.

predicted, predicted minus measured vs. tensile and compressive stress).

Confirmation of the approved models' applicability up through the projected end of cycle burnup for the Optimized ZIRLOTM fuel rods must be completed prior to their initial batch loading and prior to the startup of subsequent cycles. For example, prior to the first batch application of Optimized ZIRLOTM, sufficient LTA data may only be available to confirm the models' applicability up through 45 GWd/MTU. In this example, the licensee would need to confirm the models up through the end of the initial cycle. Subsequently, the licensee would need to confirm the models, based upon the latest LTA data, prior to re-inserting the Optimized ZIRLO"m fuel rods in future cycles. Based upon the LTA schedule, it is expected that this issue may only be applicable to the first few batch implementations since sufficient LTA data up through the burnup limit should be available within a few years.

RESPONSE: Westinghouse has provided the NRC with information related to test data and models in References 3 - 7 and 15.

The data from three cycles of operation has been evaluated, and the fuel rod creep models from fuel rod design codes have been used to predict the growth and creep performance of the samples. Through transmittal of the

Turkey Point Nuclear Plant L-2013-075 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request 226 & 10 CFR 50.12 Exemption Request Page 9 of 14 Optimized ZIRLO Fuel Rod Cladding information contained in the above mentioned letters, Westinghouse has fulfilled its obligation to provide additional data from the Optimized ZIRLOTM LTA programs to the NRC. FPL will continue to use the currently approved fuel performance models for all Optimized ZIRLOTM fuel assemblies up to the approved fuel burnup limit.

8.

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

a.

For the Westinghouse fuel design analyses:

i.

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

ii.

Between BOL up to a radiation fluence of 3.0 x 1021 n/cm 2 (E> lMeV), pseudo-irradiated Optimized ZIRLOTM strength set equal to linear interpolation between the following two strength level points: At zero fluence, strength of Optimized ZIRLOTM equal to measured strength of Optimized ZIRLOTm and at a fluence of 3.0 x 1021 n/cm2 (E> 1MeV), irradiated strength of standard ZIRLO at the fluence of 3.0 x 1021 n/cm2 (E>IMeV) minus 3 ksi.

iii.

During subsequent irradiation from 3.0 x 1021 n/cm2 up to 12 x 1021 n/cm2, the differences in strength (the difference at a fluence of 3 x 1021 n/cm 2 due to tin content) shall be decreased linearly such that the pseudo-irradiated Optimized ZIRLOTh strengths will saturate at the same properties as standard ZIRLO at 12 x 1021 n/cm 2.

b.

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

RESPONSE: Turkey Point Units 3 and 4 use a Westinghouse fuel design, and therefore, condition 8.b does not apply.

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

Turkey Point Nuclear Plant L-2013-075 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request 226 & 10 CFR 50.12 Exemption Request Page 10 of 14 Optimized ZIRLO Fuel Rod Cladding will confirm that the requirements of this condition will be met as it applies to Turkey Point Units 3 and 4.

9.

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

RESPONSE: Turkey Point Units 3 and 4 are not licensed with LOCBART or STRIKIN-IT. Therefore, this Condition does not apply.

10.

Due to the absence of high temperature oxidation data for Optimized ZIRLOTM, the Westinghouse coolability limit on PCT during the locked rotor event shall be [proprietary limits included in topical report and proprietary version of safety evaluation].

RESPONSE: The peak cladding temperature (PCT) calculated by Westinghouse for the locked rotor event has been assessed relative to the Optimized ZIRLOTM PCT limit as part of the Turkey Point Extended Power Uprate (Reference 14). This will be reassessed as part of the normal reload design process.

4.0 List of Commitments Since plant-specific TS changes are required prior to utilizing Optimized ZIRLOTM fuel rod cladding, no new commitments are necessary to support NRC approval of this license amendment request.

5.0 No Significant Hazards Determination The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazard if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

Turkey Point Nuclear Plant L-2013-075 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request 226 & 10 CFR 50.12 Exemption Request Page 11 of 14 Optimized ZIRLO Fuel Rod Cladding The proposed amendment does not involve a significant hazards consideration for the following reasons:

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

No. The proposed change would allow the use of Optimized ZIRLOTM clad nuclear fuel in the reactors. The NRC approved topical report WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A "Optimized ZIRLOTM,"

prepared by Westinghouse Electric Company LLC (Westinghouse),

addresses Optimized ZIRLOTM and demonstrates that Optimized ZIRLOTM has essentially the same properties as currently licensed ZIRLO. The fuel cladding itself is not an accident initiator and does not affect accident probability. Use of Optimized ZIRLOTM fuel cladding will continue to meet all 10 CFR 50.46 acceptance criteria and, therefore, will not increase the consequences of an accident. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

No. Use of Optimized ZIRLOTM clad fuel will not result in changes in the operation or configuration of the facility. Topical Report WCAP-12610-P-A and CENPD-404-P-A demonstrated that the material properties of Optimized ZIRLOTM are similar to those of standard ZIRLO. Therefore, Optimized ZIRLOTM fuel rod cladding will perform similarly to those fabricated from standard ZIRLO, thus precluding the possibility of the fuel becoming an accident initiator and causing a new or different type of accident. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

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

No. The proposed change will not involve a significant reduction in the margin of safety because it has been demonstrated that the material properties of the Optimized ZIRLOTM are not significantly different from those of standard ZIRLO. Optimized ZIRLO is expected to perform similarly to standard ZIRLOw for all normal operating and accident scenarios, including both loss of coolant accident (LOCA) and non-LOCA scenarios. For LOCA scenarios, where the slight difference in Optimized ZIRLOTM material properties relative to standard ZIRLOTM could have some impact on the overall accident scenario, plant-specific LOCA analyses using Optimized ZIRLO properties demonstrates that the

Turkey Point Nuclear Plant L-2013-075 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request 226 & 10 CFR 50.12 Exemption Request Page 12 of 14 Optimized ZIRLO Fuel Rod Cladding acceptance criteria of 10 CFR 50.46 has been satisfied, therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, FPL concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

6.0 Environmental Consideration 10 CFR 51.22(c)(9) provides criteria for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment of an operating license for a facility requires no environmental assessment, if the operation of the facility in accordance with the proposed amendment does not: (1) involve a significant hazards consideration, (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and (3) result in a significant increase in individual or cumulative occupational radiation exposure. FPL has reviewed this LAR and determined that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment. The basis for this determination follows.

Basis This change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons:

1. As demonstrated in the 10 CFR 50.92 evaluation, the proposed amendment does not involve a significant hazards consideration.

2. The proposed change provides a reduced corrosion rate while maintaining the benefits of mechanical strength and resistance to accelerated corrosion from abnormal chemistry conditions. Thus, the proposed amendment will not result in a significant change in the types or increase in the amounts of any effluents that may be released offsite.

3. The proposed amendment does not result in a significant increase in individual or cumulative occupational radiation exposure. There are no changes to the source term or radiological release assumptions used in evaluating the radiological consequences in the PTN UFSAR. The proposed changes have no adverse impact on component or system interactions. The proposed changes will not degrade the ability of systems, structures or components important to safety to perform their safety function nor change the response of any system, structure or component important to safety as

Turkey Point Nuclear Plant L-2013-075 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request 226 & 10 CFR 50.12 Exemption Request Page 13 of 14 Optimized ZIRLO Fuel Rod Cladding described in the PTN UFSAR. The proposed changes do not alter the design assumptions, conditions, or configurations of the facilities or the manner in which the units are operated. Hence, the proposed amendment does not result in a significant increase in individual or cumulative occupational radiation exposure.

7.0 References

1. WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOTM,

July 2006.

2. Letter from H. N. Berkow (USNRC) to J. A. Gresham (Westinghouse), "Final Safety Evaluation for Addendum I to Topical Report WCAP-126 10-P-A & CENPD-404-P-A, 'Optimized ZIRLOTM',' June 10, 2005.

3. Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance with WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, 'Optimized ZIRLOTm',"

LTR-NRC-07-1, January 4,2007.

4. Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance with WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, 'Optimized ZIRLOT M','"

LTR-NRC-07-58, November 6,2007.

5. Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance with WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, 'Optimized ZIRLOTM','"

LTR-NRC-07-58, Rev. 1, February 5, 2008.

6. Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance of WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A, 'Optimized ZIRLOTM','"

LTR-NRC-08-60, December 30, 2008.

7. Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance of WCAP-12610-P-A & CENPD-404-P-A Addendum 1 -A, 'Optimized ZIRLOT M','"

LTR-NRC-10-43, July 26, 2010.

8. J. S. Wiebe to D. A. Heacock, "North Anna Power Station, Unit Nos. 1 and 2, Exemption from the Requirements of Title 10 of the Code of Federal Regulations, Part 50, Section 50.46 and Appendix K (TAC Nos. ME3885 and ME3886),"

Dominion Serial No.11-182, Accession No. ML110601196, March 23, 2011.

9. K. Cotton to D. A. Heacock, "Surry Power Station, Unit Nos. 1 and 2, Issuance of Amendments Regarding the Use of Optimized ZIRLO Fuel Rod Cladding (TAC Nos.

ME3343 and ME 3344)," Dominion Serial No.10-669, Accession No. ML103360256, December 22, 2010

Turkey Point Nuclear Plant L-2013-075 Docket Nos. 50-250 and 50-251 Enclosure License Amendment Request 226 & 10 CFR 50.12 Exemption Request Page 14 of 14 Optimized ZIRLO Fuel Rod Cladding

10. K. Cotton to D. A. Heacock, "Surry Power Station, Unit Nos. 1 and 2, Corrections to Amendments Regarding the Use of Optimized ZIRLOTM Fuel Rod Cladding (TAC Nos. ME3343 and ME 3344)," Dominion Serial No.10-755, December 23, 2010.

11. J. Kim to D. A. Heacock, "Millstone Power Station Unit No. 3 - Issuance of Amendment Re: The Use of Optimized ZIRLOTM Fuel Rod Cladding (TAC No.

ME7663),"Accession No. ML12236A396, September 24, 2012.

12. P.S. Tam to L. J. Weber, "Donald C. Cook Nuclear Plant, Unit 1 - Issuance of Amendment Re: Use of Optimized ZIRLOTM Fuel Rod Cladding Material (TAC No.

ME5183)," Accession No. ML111610020, August 25, 2011.

13. P. S. Tam to L. J. Weber, "Donald C. Cook Nuclear Plant, Unit 2 - Issuance of Amendment Re: Use of Optimized ZIRLOTM Fuel Rod Cladding Material (TAC No.

ME7323)," Accession No. ML12138A398, August 23, 2012.

14. J. C. Paige to M. Nazar, "Turkey Point Units 3 and 4 - Issuance of Amendments Regarding Extended Power Uprate (TAC No. ME4907 and ME4908)," Accession No. ML11293A365, June 15, 2012.

15. Letter from James A. Gresham (Westinghouse) to USNRC, "SER Compliance of WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A, 'Optimized ZIRLO LTR-NRC-13-6, February 25, 2013.

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 License Amendment Request 226 & 10 CFR 50.12 Exemption Request Optimized ZIRLO Fuel Rod Cladding L-2013-075 Page 1 of 6 ATTACHMENT 1 REQUEST FOR EXEMPTION FROM THE PROVISIONS OF 10 CFR 50.46 AND 10 CFR PART 50 APPENDIX K TO ALLOW USE OF OPTIMIZED ZIRLOTM FUEL CLADDING

Turkey Point Nuclear Plant L-2013-075 Docket Nos. 50-250 and 50-251 License Amendment Request 226 & 10 CFR 50.12 Exemption Request Page 2 of 6 Optimized ZIRLO Fuel Rod Cladding

1.0 Purpose and Scope

Florida Power & Light Company (FPL) requests an exemption from the provisions of 10 CFR 50.46, "Acceptance Criteria for Emergency Core Cooling Systems for Light-Water Nuclear Power Reactors," and Appendix K to 10 CFR Part 50, "ECCS Evaluation Models" to allow the use of Optimized ZIRLOTM fuel rod cladding in future core reload applications for Turkey Point Units 3 and 4. The regulation in 10 CFR 50.46 contains acceptance criteria for the emergency core cooling system (ECCS) for reactors that have fuel rods fabricated either with Zircaloy or ZIRLO cladding. Appendix K to 10 CFR Part 50, paragraph I.A.5, requires the Baker-Just equation to be used to predict the rates of energy release, hydrogen concentration, and cladding oxidation for the metal-water reaction. The Baker-Just equation assumed the use of a zirconium alloy different than Optimized ZIRLOTM material. Therefore, an exemption to 10 CFR 50.46 and 10 CFR Part 50 Appendix K is required to support the use of Optimized ZIRLOTM fuel rod cladding. The exemption request relates solely to the cladding material specified in these regulations (i.e., fuel rods with Zircaloy or ZIRLO cladding). This request will provide for the application of the acceptance criteria of 10 CFR 50.46 and Appendix K to 10 CFR Part 50 to fuel assembly designs utilizing Optimized ZIRLOTM fuel rod cladding.

2.0 Background Information Optimized ZIRLOTM was developed to meet the needs of longer operating cycles with increased fuel discharge burnup and fuel duty. Optimized ZIRLO"m fuel cladding is different from standard ZIRLO in two respects: 1) the tin content is lower; and 2) the microstructure is different. This difference in tin content and microstructure leads to differences in some material properties. Optimized ZIRLOTM provides a reduced corrosion rate while maintaining the benefits of mechanical strength and resistance to accelerated corrosion from abnormal chemistry conditions. In addition, fuel rod internal pressure (resulting from the increased fuel duty, use of integral fuel burnable absorbers, and corrosion/temperature feedback effects) have become more limiting with respect to fuel rod design criteria. Reducing the associated corrosion buildup and thus minimizing temperature feedback effects provides additional margin to the fuel rod internal pressure design criterion.

3.0 Technical Justification of Acceptability Westinghouse Electric Company LLC (Westinghouse) topical report WCAP-126 10-P-A

& CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOTM" (Reference 1), provides the details and results of testing of Optimized ZIRLOTM material compared to standard ZIRLO material as well as the material properties to be used in various models and methodologies when analyzing Optimized ZIRLO~m fuel rod cladding. The Nuclear Regulatory Commission (NRC) Safety Evaluation (SE) (Reference 2) for the topical report contains ten conditions and limitations. The first condition requires an exemption from 10 CFR 50.46 and 10 CFR Part 50, Appendix K (which is being requested via this

Turkey Point Nuclear Plant L-2013-075 Docket Nos. 50-250 and 50-251 License Amendment Request 226 & 10 CFR 50.12 Exemption Request Page 3 of 6 Optimized ZIRLO Fuel Rod Cladding letter). Westinghouse has provided the NRC with information related to test data and models (References 3 thru 8) to address conditions and limitations 6 and 7. Condition and limitation 9 does not apply because Turkey Point Units 3 and 4 are not licensed with LOCBART or STRIKIN-II. The remaining conditions and limitations are addressed in the Turkey Point Technical Specification (TS) changes and evaluations required to support core reload activities. Since plant-specific TS changes are required prior to utilizing Optimized ZIRLOTm fuel rod cladding, no new commitments are necessary to support NRC approval of this exemption request.

The reload evaluations will ensure that acceptance criteria are met for insertion of assemblies with fuel rods clad with Optimized ZIRLOTM material. These assemblies will be evaluated using NRC approved methods and models to address the use of Optimized ZIRLOTm fuel rod cladding.

4.0 Justification of Exemption 10 CFR 50.12, "Specific exemptions," states that the NRC may grant exemptions from the requirements of the regulations of this part provided two conditions are met. These are: 1) authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security; 2) the Commission will not consider granting an exemption unless special circumstances are present.

The requested exemption to allow the use of Optimized ZIRLOTM fuel rod cladding material rather than Zircaloy or ZIRLO material for core reload applications at Turkey Point Units 3 and 4 satisfies these criteria as described below.

Condition 1:

1. This exemption is authorized by law This exemption allows the use of Optimized ZIRLOTM fuel rod cladding material at Turkey Point. As stated above, 10 CFR 50.12 allows the NRC to grant exemptions from the requirements of 10 CFR 50. Granting this proposed exemption would not result in a violation of the Atomic Energy Act of 1954, as amended, or the Commission's regulations. Therefore, the exemption is authorized by law.

Further, it should be noted that, by submitting this exemption request, Turkey Point Units 3 and 4 do not seek an exemption from the acceptance and analytical criteria of 10 CFR 50.46 and 10 CFR Part 50, Appendix K. The intent of the request is solely to allow the use of criteria set forth in these regulations for application to the Optimized ZIRLOTM fuel rod cladding material.

2. This exemption will not present an undue risk to public health and safety The reload evaluations will ensure that acceptance criteria are met for the insertion of assemblies with fuel rods clad with Optimized ZIRLOm material. Fuel assemblies using Optimized ZIRLOTM fuel rod cladding will be evaluated using NRC-approved analytical methods and plant-specific models to address the changes in the cladding

Turkey Point Nuclear Plant L-2013-075 Docket Nos. 50-250 and 50-251 License Amendment Request 226 & 10 CFR 50.12 Exemption Request Page 4 of 6 Optimized ZIRLO Fuel Rod Cladding material properties. The safety analysis for Turkey Point Units 3 and 4 are supported by the applicable site specific TSs. Reload cores are required to be operated in accordance with the operating limits specified in the TSs. Thus, the granting of this exemption request will not pose an undue risk to public health and safety.

3. This exemption is consistent with common defense and security As noted above, the exemption request is only to allow the application of the aforementioned regulations to an improved fuel rod cladding material. All the requirements and acceptance criteria will be maintained. The special nuclear material in these assemblies is required to be handled and controlled in accordance with approved procedures. Use of full regions of Optimized ZIRLOTM fuel rod cladding in the Turkey Point Units 3 and 4 cores will not affect plant operations and is consistent with common defense and security.

Condition 2:

10 CFR 50.12(a)(2) states that the NRC will not consider granting an exemption to the regulations unless special circumstances are present. The requested exemption meets the special circumstances of 10 CFR 50.12(a)(2)(ii) which states that, "Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule." In this particular circumstance, application of the subject regulations is not necessary to achieve the underlying purpose of the rule.

10 CFR 50.46 identifies acceptance criteria for ECCS performance at nuclear power plants. Due to the similarities in the properties of Optimized ZIRLOTM material and standard ZIRLO material, the current ECCS analysis approach remains applicable.

Westinghouse will perform an evaluation of the Turkey Point Units 3 and 4 core using Loss of Coolant Accident (LOCA) methods approved for the site to ensure that assemblies with Optimized ZIRLOTM fuel rod cladding material meet all LOCA safety criteria.

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

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

Turkey Point Nuclear Plant L-2013-075 Docket Nos. 50-250 and 50-251 License Amendment Request 226 & 10 CFR 50.12 Exemption Request Page 5 of 6 Optimized ZIRLO Fuel Rod Cladding ZIRLO cladding. 10 CFR 50.46 and 10 CFR Part 50, Appendix K do not apply to the proposed use of Optimized ZIRLOTM fuel rod cladding material since Optimized ZIRLOTM material has a slightly different composition than Zircaloy or ZIRLO material. With the approval of this exemption request, these regulations will be applied to Optimized ZIRLO'm fuel rod cladding.

In order to support the use of Optimized ZIRLOTM fuel rod cladding material, an exemption from the requirements of 10 CFR 50.46 and 10 CFR Part 50, Appendix K is requested. As required by 10 CFR 50.12, the requested exemption is authorized by law, does not present undue risk to public health and safety, and is consistent with common defense and security. Approval of this exemption request does not violate the underlying purpose of the rule. In addition, special circumstances do exist to justify the approval of an exemption from the subject requirements.

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

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

'Optimized ZIRLOTM'," June 10, 2005.

3. Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance with WCAP-126 10-P-A & CENPD-404-P-A, Addendum 1-A, 'Optimized ZIRLOTM'," LTR-NRC-07-1, January 4, 2007.

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

5. Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance with WCAP-12610-P-A & CENPD-404-P-A, Addendum 1 -A, 'Optimized ZIRLOTM'," LTR-NRC-07-58, Rev. 1, February 5, 2008.

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

7. Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance of WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A, 'Optimized ZIRLO TM'," LTR-NRC-10-43, July 26,2010.

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 License Amendment Request 226 & 10 CFR 50.12 Exemption Request Optimized ZIRLO Fuel Rod Cladding L-2013-075 Page 6 of 6

8. Letter from James A. Gresham (Westinghouse) to USNRC, "SER Compliance of WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A, 'Optimized ZIRLO

'," LTR-NRC-13-6, February 25, 2013.

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 License Amendment Request 226 & 10 CFR 50.12 Exemption Request Optimized ZIRLO Fuel Rod Cladding L-2013-075 Page 1 of 3 ATTACHMENT 2 TECHNICAL SPECIFICATION MARKUPS

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2013-075 License Amendment Request 226 & 10 CFR 50.12 Exemption Request Optimized ZIRLO Fuel Rod Cladding Page 2 of 3 DESIGN FEATURES 5.3 REACTOR CORE FUEL ASSEMBLIES 5.3.1 The shall contain 157 fuel assemblies with each fuel assembly containing 204 fuel rods clad with Zircaloy-4 f IR*:96, except that replacement of fuel rods by filler rods consisting of stainless steel, or by vacant rod positions, may be made in fuel assemblies if justified by cycle-specific reload analysis using NRC-approved methodology. The reactor core contains approximately 71 metric tons of uranium in the form of natural or slightly enriched uranium dioxide pellets. Each fuel rod shall have a nominal active fuel length of 144 inches. Should more than 30 individual rods in the core, or 10 fuel rods in any fuel assembly, be replaced per refueling, a Special Report discussing the rod replacements shall be submitted to the Commission within 30 days after cycle startup.

CONTROL ROD ASSEMBLIES 5.3.2 The core shall contain 45 full-length control rod assemblies. The full-length control rod assemblies shall contain a nominal 142 inches of absorber material. The absorber material shall be silver, indium, and cadmium.

All control rods shall be clad with stainless steel tubing.

5.4 DELETED TURKEY POINT - UNITS 3 & 4 5-4 AMENDMENT NOS. 251 AND 247

Turkey Point Nuclear Plant Docket Nos. 50-250 and 50-251 L-2013-075 License Amendment Request 226 & 10 CFR 50.12 Exemption Request Optimized ZIRLO Fuel Rod Cladding Page 3 of 3

18. WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO""', July 2006.

ADMINISTRATIVE CONTROLS

3.

WCAP-1 0054-P-A, Addendum, Revision 1 (proprietary), "Addendum to the Westinghouse Small Break ECCS Evaluation Model sing the NOTRUMP Code: Safety Injection into the Broken Loop and COSI Condensation odel," July 1997.

4.

WCAP-1 6009-P-A, "Realistic L "ge-break LOCA Evaluation Methodology Using the Automated Statistical Treatment of Uncerta ity Method (ASTRUM)", January 2005.

5.

USNRC Safety Evaluation Repc rt, Letter from R. C. Jones (USNRC) to N. J. Liparulo (WD, "Acceptance for Referencing of he Topical Report WCAP-12945(P) 'Westinghouse Code Qualification Document for Best Estimate Loss of Coolant Analysis,' " June 28, 1996.**

6.

Letter dated June 13, 1996, fro N. J. Liparulo (W to Frank R. Orr (USNRC), "Re-Analysis Work Plans Using Final Best Estimate Methodology.""

7.

WCAP-1 2610-P-A, "VANTAGE Fuel Assembly Reference Core Report," S. L. Davidson and T. L. Ryan, April 1995.

The analytical methods used to determine Overtemperature AT and Overpower AT shall be those previously reviewed and approved by the NRC in:

1.

WCAP-8745-P-A, " Design Basis for the Thermal Overtemperature AT and Overpower AT Trip Functions," September 1986

2.

WCAP-9272-P-A, "Westinghouse Reload Safety Evaluation Methodology," July 1985 The analytical methods used to determine Safety Limits, Shutdown Margin - Tav > 200°F, Shutdown Margin -

Tavg < 200°F, Moderator Temperature Coefficient, DNB Parameters, Rod Bank Insertion Limits and the All Rods Out position shall be those previously reviewed and approved by the NRC in:

1.

WCAP-9272-P-A, "Westinghouse Reload Safety Evaluation Methodology," July 1985.

The ability to calculate the COLR nuclear design parameters are demonstrated in:

1.

Florida Power & Light Company Topical Report NF-TR-95-01, "Nuclear Physics Methodology for Reload Design of Turkey Point & St. Lucie Nuclear Plants."

Topical Report NF-TR-95-01 was approved by the NRC for use by Florida Power & Light Company in:

1.

Safety Evaluation by the Office of Nuclear Reactor Regulations Related to Amendment No. 174 to Facility Operating License DPR-31 and Amendment No. 168 to Facility Operating License DPR-41, Florida Power & Light Company Turkey Point Units 3 and 4, Docket Nos. 50-250 and 50-251.

The AFD, FQ(Z), FH, K(Z), Safety Limits, Overtemperature AT, Overpower AT, Shutdown Margin - Tw > 200°F, Shutdown Margin -T,, < 200°F, Moderator Temperature Coefficient, DNB Parameters, and Rod Bank Insertion Limits shall be determined such that all applicable limits of the safety analyses are met. The CORE OPERATING LIMITS REPORT, including any mid-cycle revisions or supplements thereto, shall be provided upon issuance, for each reload cycle, to the NRC Document Control Desk with copies to the Regional Administrator and Resident Inspector, unless otherwise approved by the Commission.

• • As evaluated in NRC Safety Evaluation dated December 20, 1997.

TURKEY POINT - UNITS 3 & 4 6-22 AMENDMENT NOS. 249 AND 245