Text

License Amendment Request and 10 CFR 50.12 Exemption Request for Use of Optimized Zirlo Fuel Rod Cladding
	ML15295A016
Person / Time
Site:	Catawba, McGuire, Mcguire
Issue date:	08/20/2015
From:	Repko R; Duke Energy Carolinas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RA-15-0020
	Download: ML15295A016 (29)
	v • d • e

~ UKE 26SouthChurh Street

\.YENERGY, Chadoote NC 28202 Mailing Address:

Mail Code ECOTH/P.O. Box 1006 Chadolte, NC 28201-1006 704.382-4126 10 CFR 50.12 10 CFR 50.90 Serial: RA-1 5-0020 August 20, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-000 1 CATAWBA NUCLEAR STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-413 AND 50-414 / RENEWED LICENSE NOS. NPF-35 AND NPF-52 MCGUIRE NUCLEAR STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-369 AND 50-370 / RENEWED LICENSE NOS. NPF-9 AND NPF-17

SUBJECT:

LICENSE AMENDMENT REQUEST AND 10 CFR 50.12 EXEMPTION REQUEST FOR USE OF OPTIMIZED ZIRLOTM FUEL ROD CLADDING

REFERENCES:

1. WCAP-12610-P-A, VANTAGE+#FuelAssembly Reference Core Report, April 1995

2. WCP-1260-P-A &CENPD-404-P-A, Addendum 1-A, Optimized ZlRLO , July 2006 (ADAMS Accession No. ML062080563)

In accordance with the provisions of 10 CFR 50.90, Duke Energy Carolinas, LLC, referred to henceforth as "Duke Energy" requests amendments, in the form of changes to the Technical Specifications (TS) to Renewed Facility Operating Licenses NPF-35 and NPF-52 for Catawba Nuclear Station Units 1 and 2 (CNS) and Renewed Facility Operating Licenses NPF-9 and NPF-17 for McGuire Nuclear Station Units 1 and 2 (MNS). The proposed change will add Optimized ZIRLOTM High Performance Fuel Cladding 1 as an allowable fuel rod cladding material to TS 4.2.1. In addition, Duke Energy proposes to add the Westinghouse VANTAGE+ fuel assembly reference core report (Reference 1) and the topical report on Optimized ZlRLOTM (Reference 2) to the TS 5.6.5.b list of analytical methods used to determine the core operating limits. These changes are consistent with the Nuclear Regulatory Commission (NRC) allowed use of Optimized ZlRLOT~fuel cladding material as documented in the Safety Evaluation included in Reference 2.

To support this change to allow the use of Optimized ZIRLOTM, in accordance with 10 CFR 50.12, Duke Energy 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

' Optimized ZIRLO and ZIRLO are trademarks or registered trademarks of Westinghouse Electric Company LLC, its affiliates and/or its subsidiaries in the Unites States of America and may be registered in other countries throughout the world. All rights reserved. Unauthorized use is strictly prohibited. Other names may be trademark of their respective owners.

U.S. Nuclear Regulatory Commission RA-1 5-0020 Page 2 reactors," and Appendix K to 10 CER 50, "ECCS Evaluation Models," for ONS and MNS. The exemption request relates solely to the specific types of cladding material specified in these regulations for use in light water reactors. As written, the regulations presume use of either Zircaloy or ZIRLO High Performance Fuel Cladding 1 . The exemption request is required since Optimized ZlRLOTM has a slightly different composition than Zircaloy or standard ZIRLO.

Enclosure 1 provides an evaluation of the proposed change. Exemption Requests for CNS and MNS are included in Enclosure 2. Marked-up Technical Specifications, reflecting the proposed change in this submittal, are included in Enclosures 3 and 4. Reprinted (clean) TS pages will be provided to the NRC prior to issuance of the approved amendment.

The proposed changes have been evaluated in accordance with 10 CER 50.91 (a)(1) using criteria in 10 CFR 50.92(c), and it has been determined that the proposed changes involve no significant hazards consideration.* The bases for these determinations are included in Enclosure 1.

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

Revisions to the CNS and MNS Updated Final Safety Analysis Reports (UFSAR), necessary to reflect approval of this submittal, will be made in accordance with 10 CFR 50.71(e), with approved exemptions.

Approval of the proposed amendment and exemption request is requested by August 20, 2016.

Approval within the requested timeframe will support potential application for the proposed use of Optimized ZIRLOTM fuel rod cladding material in the scheduled Spring 2017 MNS Unit 2 and CNS Unit 1 refueling outages. Once approved, the amendment will be implemented within 120 days.

In accordance with 10 CFR 50.91, Duke Energy is notifying the States of North Carolina and South Carolina of this license amendment and exemption request by transmitting a copy of this letter and enclosures to the designated State Officials.

Should you have any questions concerning this letter, or require additional information, please contact Art Zaremba, Manager - Nuclear Fleet Licensing, at 980-373-2062.

'Optimized ZIRLO and ZIRLO are trademarks or registered trademarks of Westinghouse Electric Company LLC, its affiliates and/or its subsidiaries in the Unites States of' America and may be registered in other countries throughout the world. All rights reserved. Unauthorized use is strictly prohibited. Other names may be trademark of their respective owners.

U.S. Nuclear Regulatory Commission RA-1 5-0020 Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on August 20, 2015.

Sincerely, Regis T. Repko Senior Vice President - Governance, Projects and Engineering NDE

Enclosures:

1. Evaluation of the Proposed Change

2. Exemption Request

3. Proposed McGuire Technical Specifications Changes (Mark-up)

4. Proposed Catawba Technical Specifications Changes (Mark-up)

U.S. Nuclear Regulatory Commission RA-1 5-0020 Page 4 cc: USNRC Region II G. A. Hutto, III, USNRC Resident Inspector - CNS J. Zeiler, USNRC Resident InspeCtor - MNS G. E. Miller, NRR Project Manager - CNS & MNS W. L. Cox, Ill, Section Chief, North Carolina Department of Health and Human Services, RP Section (NC)-

S. E. Jenkins, Manager, Radioactive and Infectious Waste Management (SC)

Chairman, North Carolina Utilities Commission

U.S. Nuclear Regulatory Commission RA-1 5-0020 Page 5 bcc: Chris Nolan Art Zaremba Nicole Edwards Scott Thomas David Cummings File: (Corporate)

Electronic Licensing Library (ELL)

Kelvin Henderson Cecil Fletcher, II Tolani Owusu North Carolina Municipal Power Agency No. 1 (NCMPA)

Piedmont Municipal Power Agency (PMPA)

North Carolina Electric Membership Corporation (NCEMC)

CNS Master File 801.01 - CNO4DM T. K. Pasour (For CNS Licensing/Nuclear Records)

Steven Capps Jeff Robertson PT Vu MNS Master File 801.01 - MGo2DM K. L. Crane (For MNS Licensing/Nuclear Records)

Enclosure 1 to RA-1 5-0020 Page 1 of 12 Enclosure 1 Evaluation of the Proposed Change

Subject:

This license amendment request (LAR) includes a proposed change to revise the Technical Specifications to allow the use of Optimized ZIRLOTM fuel rod cladding material.

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION

3. TECHNICAL EVALUATION

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination 4.4 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES

Enciosure 1 to RA-1 5-0020 Page 2 of 12

1.

SUMMARY

DESCRIPTION Duke Energy proposes to revise the Technical Specifications (TS) for Catawba Nuclear Station Units 1 and 2 (CNS) and McGuire Nuclear Station Units 1 and 2 (MNS) to allow the use of an additional fuel rod cladding material, Optimized ZIRLOTM High Performance Fuel Cladding.

The current acceptable fuel rod cladding materials are identified in Technical Specification 4.2.1, "Fuel Assemblies." A change to the References of Technical Specification 5.6.5, "Core Operating Limits Report (COLR)," is also proposed, to add the VANTAGE+ fuel assembly core reference report and the topical report for Optimized ZIRLOTM to the list of analytical models and methods used to determine the core operating limits previously reviewed and approved by the U.S. Nuclear Regulatory Commission (NRC).

In addition to the proposed TS changes, an exemption from the provisions of 10 CFR 50.46, "Acceptance criteria for emergency core cooling systems for lighthwater nuclear power reactors,"

and Appendix K to 10 CFR Part 50, "ECCS Evaluation Models," is required to support the use of this additional fuel rod cladding material. The exemption request for CNS and MNS is provided in Enclosure 2 of this submittal.

Optimized ZIRLOTMI was developed to meet the needs of longer operating cycles with increased fuel discharge burnup and fuel duty. Optimized ZIRLOTM fuel cladding is different from standard ZIRLO High Performance Fuel Cladding' 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) has 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.

2. DETAILED DESCRIPTION A specific description of each change is provided below. In addition, TS mark-ups are provided in Enclosures 3 and 4.

2.1 CNS and MNS Technical Specification 4.2.1, Fuel Assemblies:

This section is being revised to add the Westinghouse Electric Company, LLC (Westinghouse) Optimized ZIRLOTM alloy to the list of materials that may be used as the fuel rod cladding in CNS and MNS fuel assemblies. The proposed revised specification (with changes in bold and strikethroughs) reads as follows:

The reactor shall contain 193 fuel assemblies. Each assembly shall consist of a matrix of either Z- L-O*--e Zircalloy, ZlRLO, or Optimized ZlRLOTM clad fuel rods with an initial composition of natural or slightly enriched uranium dioxide (U0 2 ) as fuel material. Limited substitutions of ZlRLO ', Optimized ZlRLOh Z4LOM zirconium alloy, or stainless steel filler rods for fuel rods, in accordance SOptimized ZIRLO and ZIRLO are trademarks or registered trademarks of Westinghouse Electric Company LLC, its affiliates and/or its subsidiaries in the Unites States of America and may be registered in other countries throughout the world. All rights reserved. Unauthorized use is strictly prohibited. Other names may be trademark of their respective owners.

Enclosure 1 to RA-1 5-0020 Page 3 of 12 with approved applications of fuel rod configurations, may be used. Fuel assemblies shall be limited to those fuel designs that have been analyzed with applicable NRC staff approved codes and methods and shown by tests or analyses to comply with all fuel safety design bases. A limited number of lead test assemblies that have not completed representative testing may be placed in nonlimiting core regions.

2.2 CNS Technical Specification 5.6.5, CORE OPERATING LIMITS REPORT (CO LR):

This section currently includes eighteen documents that define the methods used to determine the core operating limits for CNS. The proposed revision to this list of references would add Reference 19, the VANTAGE+ Fuel Assembly Reference Core Report (Reference 1) due to the current use of ZIRLO in TS 4.2.1, and Reference 20, the topical report for Optimized ZIRLOTM (Reference 2) to TS 5.6.5.b, as follows:

18. DPC-NE-1 007-PA, "Conditional Exemption of the EOC MTC Measurement Methodology," (Duke and Westinghouse Proprietary).

19. WCAP-1 261 0-P-A, "VANTAGE+ Fuel Assembly Reference Core Report," April 1995. (Westinghouse Proprietary).

20. WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOuI, July 2006. (Westinghouse Proprietary).

2.3 MNS Technical Specification 5.6.5, CORE OPERATING LIMITS REPORT (COLR):

This section currently includes seventeen documents that define the methods used to determine the core operating limits for MNS. The proposed revision to this list of references would add Reference 18, the VANTAGE+ Fuel Assembly Reference Core Report (Reference 1) due to the current use of ZlRLO in TS 4.2.1, and Reference 19, the topical report for Optimized ZlRLOTM (Reference 2) to TS 5.6.5.b, as follows:

17. DPC-NE-1007-PA, "Conditional Exemption of the EOC MTC Measurement Methodology" (Duke and Westinghouse Proprietary).

18. WCAP-1 261 0-P-A, "VANTAGE. Fuel Assembly Reference Core Report," April 1995. (Westinghouse Proprietary).

19. WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOTM,' July 2006. (Westinghouse Proprietary).

3. TECHNICAL EVALUATION Westinghouse has performed an evaluation of the CNS and MNS cores using Loss of Coolant Accident (LOCA) methods approved for the sites to ensure that assemblies with Optimized ZIRLOTM fuel rod cladding material meet all LOCA safety criteria. The above reference, WCAP-12610-P-A, VANTAGE+ Fuel Assembly Reference Core Report (Reference 1) is being added to the COLR, due to a previous omission. The identification of this inadvertent omission was entered into the corrective action program.

to RA-1 5-0020 Page 4 of 12 Optimized ZIRLOTM is described in the Westinghouse topical report WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, Optimized ZIRLOTM (Reference 2). The NRC staff's Safety Evaluation (SE) for Optimized ZIRLOTM (Reference 3) requires that licensees referencing Addendum 1-A to implement Optimized ZIRLOTM comply with the ten conditions and limitations listed within the SE.

The ten conditions and limitations laid out in the NRC's SE for WCAP-1 2610-P-A and CENPO-404-P-A, Addendum 1-A (Reference 3) are listed below. Duke Energy 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 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 Enclosure 2 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 timethat a new fuel rod burnup limit is approved for use. CNS and MNS use a Westinghouse fuel design; therefore, the burnup limit for CE fuel designs is not applicable.

3. The maximum fuel rod waterside corrosion, as predicted by the best-estimate model, will[]

of hydrides for all locations of the fuel rod.

RESPONSE: Duke Energy confirms, as part of the normal reload process, that the maximum fuel rod waterside corrosion for fuel using Optimized ZIRLOTM fuel rod cladding is 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 ZIRLOTM and Zircaloy-4 fuel analysis will continue to be met, except that the use of Optimized ZIRLOTM cladding in addition to standard ZIRLOTM and Zircaloy-4 cladding is now approved.

3/4 RESPONSE: The fuel analysis of Optimized ZIRLOTM fuel rod cladding will continue to meet all conditions associated with approved methods. For CNS and MNS, this is a current to RA-1 5-0020 Page 5 of 12

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 ZIRLOTM and Optimized ZIRLOTM data were acceptable and for which the verifications discussed in Addendum 1 and responses to RAIs were performed.

RESPONSE: The application of ZIRLO and Optimized ZIRLOTM cladding in approved methodologies will be made consistent with the approach accepted in WCAP-1261 0-P-A &

CENPD-404-P-A, Addendum 1-A, Optimized ZIRLOTM, July 2006. For CNS and MNS, 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 data from Byron, Calvert Cliffs, Catawba, and Millstone.

i. Visual ii. Oxidation of fuel rods iii. Prof ilometry 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 bumup 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 ZIRLOTM 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 6 of this enclosure (References 4-10).

Lead Test Assembly (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 cladding LTA programs to the NRC. Duke Energy has confirmed that the requirements of this condition

Enclosure 1 to RA- 15-0020 Page 6 of 12 have been met as it applies to ONS and MNS.

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

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

Confirmation of the approved models' applicability up through the projected end of cycle bumup 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 Ucensee would need to confirm the models up through the end of the initial cycle. Subsequently, the licensee would need to confirm the models, based upon the latest LTA data, prior to re-inserting the Optimized ZIRLOTM fuel rods in future cycles. Based upon the 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 bumup 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 references in Section 6 of this enclosure (References 4-10).

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 information contained in the above mentioned letters, Westinghouse has fulfilled its obligation to provide additional data regarding test data and performance models to the NRC. Duke Energy has confirmed that the requirements of this condition have been met as it applies to CNS and MNS.

8. The licensee shall account for the relative differences in unirradiated strength (YS and UTS) between Optimized ZIRLOTM and standard ZlRLOTM in cladding and structural analyses until irradiated data for Optimized ZIRLOTM 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>I MeV),

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 to RA-1 5-0020 Page 7 of 12 ZIRLOTM and at a fluence of 3.0 X 1021 n/cm2 (E>I MeV), irradiated strength of standard ZIRLOTM at the fluence of 3.0 X 1021 n/cm 2 (E>I1MeV) minus 3 ksi.

iii. During subsequent irradiation from 3.0 X 1021 n/cm 2 up to 12 x 10~21 n/cm2 , the differences in strength (the difference at a fluence of 3.0 X 1021 n/cm 2 due to tin content) shall be decreased linearly such that the pseudo-irradiated Optimized ZIRLOTM strengths will saturate at the same properties as standard ZIRLOTM at 12 x 1021 n/cm 2 .

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

RESPONSE: The fuel analysis of Optimized ZIRLOTM 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 ZlIRLOTM cladding strengths have been collected and provided to the NRC. Duke Energy confirms, as part of the normal reload process, that the requirements of this condition are met as it applies to CNS and MNS.

CNS and MNS use a Westinghouse fuel design, and therefore, condition 8.b does not apply.

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 ref lood, the limiting LOCBART or STRIKIN-Il calculation will be rerun using the specified Optimized ZlRLOTM 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: CNS and MNS are not licensed with LOCBART or STRIKIN-Il. 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: Duke Energy's methodology for evaluating the Locked Rotor accident for ONS and MNS has been approved by the NRC, and is documented in the NRC staff's Safety Evaluation (SE) for the Methodology Report DPC-NE-3002-A, Revision 4 (Reference 11). Per DPC-NE-3002, Duke Energy's transient analysis methodology does not have an explicit acceptance criteria for peak cladding temperature during the Locked Rotor event. The core cooling capability analysis determines to what extent fuel cladding integrity is compromised by calculating the number of fuel rods that exceed the 95/95 DNBR limit. Duke Energy does not request any changes to our existing licensing basis, and the Locked Rotor core coolability for Optimized ZlRLOTM cladding is evaluated in accordance with the existing DNBR criteria.

Enclosure 1 to RA- 15-0020 Page 8 of 12

4. REGULATORY EVALUATION 4.1 ,Applicable Reaqulatorv Reqiuirements/Criteria 10 CFR 50.46 provides acceptance criteria for emergency core cooling systems for light-water nuclear power reactors. Appendix K to Part 50 establishes the required and acceptable features of the ECCS evaluation models. By letter dated June 10, 2005, the NRC staff issued a safety evaluation approving Addendum 1 to Westinghouse Topical Report WCAP-1 2610-P-A and CEN P0-404-P-A, Optimized ZIRLOTM, wherein the NRC staff approved the use of Optimized ZIRLOTM as an acceptable fuel cladding material for Westinghouse and Combustion Engineering (CE) fuel designs.

Duke Energy evaluated the proposed changes to determine whether applicable regulations and requirement continue to be met. This determination found that the proposed change to allow the use of Optimized ZI RLOTM fuel rod cladding material requires an exemption from 10 CFR 50.46, "Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors"; and 10 CFR 50, Appendix K, "ECCS Evaluation Models". provides the basis and justification for exemption from these regulations.

4.2 Precedent As part of the industry focus to minimize the potential for fuel failure, several licensees have received staff approval to use Optimized ZIRLOTM. Florida Power & Light has received approval at Turkey Point, Units 3 and 4 (Reference 12). NextEra Energy Seabrook, LLC, has received approval at Seabrook Station, Unit 1 (Reference 13). Dominion has also received approval at North Anna Power Station, Units 1 and 2 (Reference 14).

4.3 No Significant Hazards Consideration Determination Duke Energy is requesting an amendment to the Renewed Facility Operating Licenses NPF-35 and NPF-52 for Catawba Nuclear Station Units 1 and 2 (CNS) and Renewed Facility Operating Licenses NPF-9 and NPF-17 for McGuire Nuclear Station Units 1 and 2 (MNS) to add Optimized ZIRLOTM as an allowable fuel rod cladding material to the Technical Specifications (TS), as well as, adding the Westinghouse VANTAGE+ fuel assembly reference core report and topical report on Optimized ZIRLOTM to the TS 5.6.5.b list of analytical methods used to determine the core operating limits.

Duke Energy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:

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

Response: No.

The proposed TS changes add flexibility in the selection of fuel rod cladding materials for use at ONS and MNS. The proposed change of adding a cladding material does not result in an increase to the probability or consequences of an accident previously evaluated. TS 4.2.1 addresses the fuel assembly design, and cretyseiista"Ecasebyshall consist of a matrix of either ZIRLO'~ or Zircaloy fuel rods...". The proposed change will add Optimized ZIRLOTM to the approved fuel rod cladding materials listed in this TS. In addition, a reference to the Westinghouse VANTAGE+ fuel assembly core reference report, WCAP-1261 0-P-A, to RA- 15-0020 Page 9 of 12 and the topical report for Optimized ZIRLOTM, WCAP-1 261 0-P-A and CENPD-404-P-A, Addendum 1-A, will be included in the listing of approved methods used to determine the core operating limits for CNS and MNS given in TIS 5.6.5.b.

Westinghouse topical report WCAP-1261 0-P-A and CENPD-404-P-A, Addendum 1-A, Optimized ZIRLOTM, provides the details and results of material testing of Optimized ZIRLOTM compared to standard ZIRLO,as well as the material properties to be used in various models and methodologies when analyzing Optimized ZIRLOTM. As the nuclear industry pursues longer operating cycles with increased fuel discharge burnup and fuel duty, the corrosion performance requirements for the nuclear fuel cladding become more demanding. Optimized ZIRLOTM was developed to meet these industry needs by providing a reduced corrosion rate while maintaining the composition and physical properties, such as mechanical strength, similar to standard ZIRLO@. Fuel rod internal pressure has also become more limiting due to changes such as increased fuel duty and use of integral fuel burnable absorbers. Reducing the associated corrosion .buildup by using Optimized ZIRLOTM in turn reduces temperature feedback effects, providing additional margin to the fuel rod internal pressure design criterion. Fuel with Optimized ZIRLOTM cladding will continue to satisfy the pertinent design basis operating limits, so cladding integrity is maintained. There are no changes that will adversely affect the ability of existing components and systems to mitigate the consequences of any accident. Therefore, addition of Optimized ZIRLOTM to the allowable cladding materials for CNS and MNS does not result in an increase in the probability or consequences of an accident previously evaluated.

The NRC has previously approved use of Optimized ZIRLOTM fuel cladding material in Westinghouse fueled reactors provided that licensees ensure compliance with the Conditions and Limitations set forth in the NRC Safety Evaluation for the topical report. Confirmation that these Conditions are satisfied is performed as part of the normal core reload process.

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?

Response: No.

The proposed TS changes add flexibility in the selection of fuel rod cladding materials for use at CNS and MNS. Optimized ZlRLOTM was developed to provide a reduced cladding corrosion rate while maintaining the benefits of mechanical strength and resistance to accelerated corrosion from potential abnormal chemistry conditions. The fuel rod design bases are established to satisfy the general and specific safety criteria addressed in the CNS and MNS UFSAR, Chapter 15 (Accident Analyses). The fuel rods are designed to prevent excessive fuel temperatures, excessive fuel rod internal gas pressures due to fission gas releases, and excessive cladding stresses and strains. Westinghouse topical rport WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, Optimized ZIRLO ", provides the details and results of material testing of Optimized ZIRLOM compared to standard ZIRLOci, as well as the material properties to be used in various models and methodologies when analyzing Optimized ZIRLOTM. The original fuel design basis

Enclosure 1 to RA-1 5-0020 Page 10 of 12 requirements have been maintained. No new single failure mechanisms will be created, and there are no alterations to plant equipment or procedures that would introduce any new or unique operational modes or accident precursors. Therefore, addition of another approved cladding material of similar composition and properties as the current approved cladding materials to the CNS and MNS TS does not create the possibility of a new or different kind of accident or malfunction from those previously evaluated within the UFSAR.

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

Response: 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 ZI RLOTM are not significantly different from those of standard ZI RLO*. Optimized ZIRLOTM is expected to perform similarly to standard ZIRLO 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 ZlRLOTM material properties relative to standard ZIRLO could have some impact On the overall accident scenario, plant-specific LOCA analyses using Optimized ZlRLOTM properties demonstrates that the 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, Duke Energy concludes that the proposed change 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.

4.4 Conclusions In conclusion, based on the considerations discussed above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5. ENVIRONMENTAL CONSIDERATION Duke Energy 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.

6. REFERENCES

1. WCAP-1 2610O-P-A, VANTAGE+I Fuel Assbmbly Reference Core Report, April 1995 to RA-1 5-0020 Page 11 of 12

2. WCAP-1 2610-P-A & CENPD-404-P-A, Addendum 1-A, Optimized ZIRLO TM, Accession No. ML062080563, July 2006

3. Letter from H. N. Berkow (USNRC) to J. A. Gresham (Westinghouse), Final Safety Evaluation for Addendum 1ito Topical Report WCAP-126 10-P-A & CENPD-404-P-A, Optimized ZIRLOTM, Accession No. ML051670403, June 10, 2005

4. Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, SER Compliance with WCAP- 126 10-P-A & CENPD-404-P-A Addendum 1-A 'Optimized ZIRLO TM' (Proprietary/Non-proprietaiy),LTR-NRC-07-1, Accession No. ML070100385, january 4,

-2007

5. Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, SER Compliance with WCAP- 126 10-P-A & CENPD-404-P-A Addendum 1-A Optimized ZIRLO TM (Proprietary/Non-proprietary),LTR-N RC-07-58, Accession No. ML073130556, November 6, 2007

6. Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, SER Compliance with WCAP- 12610-P-A &CENPD-404-P-A Addendum 1-A Optimized ZIRLO TM (Proprietary/Non-proprietary),LTR-NRC-07-58 Rev. 1, Accession No. ML080390451, February 5, 2008

7. Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, SER Compliance with WCAP- 12610-P-A & CENPD-404-P-A Addendum 1-,A Optimized ZIRLO TM (Proprietary/Non-proprietary),LTR-NRC-08-60, Accession No. ML090080380, December 30, 2008

8. Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, SER Compliance with WCAP- 12610-P-A & CENPD-404-P-A Addendum 1-A Optimized ZIRLO0TM (Proprietary/Non-proprietary),LTR-NRC-1 0-43, Accession No. ML102140213, July 26, 2010

9. Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, SER Compliance with WCAP-126 10O-P-A & CENPD-404-P-AAddendum 1-A Optimized ZIRLO0TM (Proprietary/Non-proprietary),LTR-N RC- 13-6, Accession No. ML13070A188, February 25, 2013

10. Letter from J. A. Gresham (Westinghouse) to USNRC (Document Control Desk), Submittal of Responses to Draft RAIs and Revisions to Select Figuresin L TR-NRC-13-6 to Fulfill Conditions 6 and 7 of the Safety Evaluation for WCAP- 12610-P-A & CENPD-404-P-A Addendum 1-A (Proprietary/Non-Proprietary),LTR-NRC- 15-7, February 9, 2015

11. Letter from C. P. Patel (USNRC) to G. R. Peterson (Duke Energy), Safety Evaluationfor Revision 4 to the Duke Energy CorporationTopical Report DPC-NE-3OO2-A, UFSAR Chapter 15 System TransientAnalysis Methodology, Accession No. ML010960306, April 2001

12. Letter from A. L. Klett to M. Nazar, Turkey Point Nuclear GeneratingUnit Nos. 3 and 4, Issuance of Amendments Regarding the Use of Optimized ZIRLOTM Fuel Rod Cladding Material(TAC Nos. MF1451 and MF1452), Accession No. ML13329A139, February 20, 2014

13. Letter from J. G. Lamb to K. Walsh, Seabrook Station, Unit No. 1, Issuance of Amendment Regarding the Use of Optimized ZlRLOTM Fuel Rod Cladding Material (TAG No. MF24 10),

Accession No. ML13213A143, March 5, 2014" to RA-1 5-0020 Page 12 of 12

14. Letter from J. S. Wiebe to D. A. Heacock, North Anna Power Station, Unit Nos. 1 and 2, Issuance of Amendments Regarding the Use of Optimized ZIRLOTM Fuel Rod Cladding (TAG Nos. ME3885 and ME3886), Accession No. ML110601196, April 14, 2011 to RA-1 5-0020 Page 1 of 6 Enclosure 2 Exemption Request Request for Exemption from the Provisions of 10 CFR 50.46 and 10 CFR Part 50 Appendix K to Allow Use of Optimized ZIRLOTM High Performance Fuel Cladding Material in Core Reload Applications Table of Contents 1.0 Purpose ................................................................... 2 2.0 Background ................. :............................................. 2 3.0 Technical Justification of Acceptability ................................. 3 4.0 Justification of Exemption ............................................... 3 5.0 Special Circumstances Support the Issuance of an Exemption.....4 6.0 Conclusion ................................................................ 5 7.0 References ................................................................ 5

Enclosure 2 to RA-1 5-0020 Page 2 of 6 Request for Exemption from the Provisions of 10 CFR 50.46 and 10 CFR Part 50 Appendix Kto Allow Use of Optimized ZlRLOTM High Performance Fuel Cladding Material in Core Reload Applications 1.0 Purpose Duke Energy Carolinas, LLC (Duke Energy) 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 Alpp endix Kto 10 CFR Part 50, "ECCS Evaluation Models" to allow the use of Optimized ZIRL.O'TM High Performance Fuel Cladding 1 in future core reload applications for Catawba Nuclear Station Units 1 and 2"(CNS) and McGuire Nuclear Station Units 1 and 2 (MNS). 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 High Performance Fuel Cladding1 material.

Appendix K to 10 CFR Part 50, paragraph L.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 ZlIRLOTM material. Section 3.5 of the NRC Safety Evaluation for Optimized ZIRLOIM allows the Baker-Just correlation to be applied to Optimized ZIRLOTM cladding, but an exemption to 10 CFR Part 50 Appendix K is required (Reference 1). 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 specific 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 Kto 10 CFR Part 50 to fuel assembly designs utilizing Optimized ZIRLOTM fuel rod cladding.

2.0 Background

As the nuclear industry pursues longer operating cycles with increased fuel discharge burnup and fuel duty, the corrosion performance requirements for the nuclear fuel cladding become more demanding. Optimized ZIRLOTM material was developed to meet these needs and provides a reduced corrosion rate while maintaining the benefits of mechanical strength and resistance to accelerated corrosion from abnormal chemistry conditions. In addition, fuel rod internal pressures (resulting from the increased fuel duty, use of integral fuel burnable absorbers, and corrosion/temperature feedback effects) have become more limiting with respect to fuel rod design criteria. Reducing the associated corrosion buildup, and thus minimizing temperature feedback effects, provides additional margin to the fuel rod internal pressure design criterion.

The reloads scheduled to contain fuel rods with Optimized ZIRLOTM cladding are proposed for Spring 2017 for McGuire Nuclear Station Unit 2 and Catawba Nuclear Station Unit 1.

' Optimized ZIRLO and ZTRLO are trademarks or registered trademarks of Westinghouse Electric Company LLC, its affiliates and/or its subsidiaries in the Unites States of America and may be registered in other countries throughout the world. All rights reserved. Unauthorized use is strictly prohibited. Other names may be trademark of their respective owners.

to RA- 15-0020 Page 3 of 6 Technical Specification (TS) changes for CNS and MNS are required to allow the use of Optimized Zl RLOTM fuel rod cladding for core reload applications. The request for these changes is provided in Enclosure 1 of this submittal.

3.0 Technical Justification of Acceptability Westinghouse Electric Company LLC (Westinghouse)~ topical report WCAP-1261 0-P-A &

CENPD-404-P-A, Addendum 1-A, Optimized ZIRLOTM (Reference 2), provides the details and results of material testing of Optimized ZIRLOTM Compared to standard ZIRLO as well as the material properties to be used in various models and methodologies when analyzing Optimized ZIRLOTM fuel rod cladding. The Nuclear Regulatory Commission (NRC) Safety Evaluation (SE)

(Reference 1) 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. Westinghouse has provided the NRC with information related to test data and models (References 3 through

9) to address Conditions and Limitations 6 and 7. Condition and Limitation 9 does not apply because CNS and MNS are not licensed with LOCBART or STRIKIN-II.

The remaining Conditions and Limitations are addressed in the CNS and MNS TS changes included in this submittal or will be addressed in evaluations required to support core reload activities.

The normal core reload evaluations will ensure that acceptance criteria are met for the insertion of assemblies with fuel rods clad with Optimized ZIRLOTM. These assemblies will be evaluated using NRC approved methods and models to address the use of Optimized ZlRLOTM 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 three conditions are met. The three conditions are: 1) the exemption is authorized by law; 2) the exemption will not present an undue risk to the health and safety of the public; and 3) the exemption is consistent with the common defense and security.

The requested exemption to allow the use of Optimized ZlRLOTM fuel rod cladding material in addition to Zircaloy or ZIRLO material for core reload applications at Catawba Nuclear Station Units 1 and 2 (CNS) and McGuire Nuclear Station Units 1 and 2 (MNS) satisfies these criteria as described below.

1. This exe mption is authorized by law As required by 10 CFR 50.12 (a)(1), this requested exemption is "authorized by law." The selection of a specified cladding material in 10 CFR 50.46 and implied in 10 CFR Part 50, Appendix K, was adopted at the discretion of the Commission consistent with its statutory authority. No statute required the NRC to adopt this specification. Additionally, the NRC has the authority under Section 50.12 to grant exemptions from the requirements of Part 50 upon showing proper justification. Further, it should be noted that, by submitting this exemption request, CNS and MNS do not seek an exemption from the acceptance and analytical criteria to RA-1 5-0020 Page 4 of 6 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 ZlRLOTM 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 ZIRLOTM 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 material properties.

The safety analyses for CNS and MNS 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 Optimized ZlRLOTM fuel rod cladding in the CNS and MNS cores will not affect plant operations and is consistent with common defense and security.

5.0 Special Circumstances Support the Issuance of an Exemption 10 CFR 50.12(a)(2) states that the N RC Will not consider granting an exemption to the regulations unless special circumstances are present. The requested exemption meets the special circumstances of 10 CFR 50.1 2(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 has performed an evaluation of the CNS and MNS cores using Loss of Coolant Accident (LOCA) methods approved for the sites 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 l.A.5 is to apply an equation for rates of energy release, hydrogen generation, and cladding oxidation from a metal-water reaction that conservatively bounds all post- LOCA scenarios (i.e., the Baker-Just equation). Application of the Baker-Just equation has been demonstrated to be appropriate for the Optimized ZIRLOTM alloy. Due to the similarities in the composition of the Optimized ZIRLOTM and standard ZIRLO to RA-1 5-0020 Page 5 of 6 fuel rod cladding materials, the application of the Baker-Just equation will continue to conservatively bound all post-LOCA scenarios.

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

10 CFR 50.46 and 10 CFR Part 50, Appendix K do not apply to the proposed use of Optimized ZJRLOTM fuel rod cladding material since Optimized ZIRLOTM material has a slightly different composition than Zircaloy or ZIRLOmaterial. With the approval of this exemption request, these regulations will be applied to Optimized ZIRLOTM 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.

7.0 References

1. Letter from H. N. Berkow (USNRC) to J. A. Gresham (Westinghouse), Final Safety Evaluation for Addendum 1 to Topical Report WCAP- 12610-P-A & CENPD-404-P-A, Optimized ZIRLOTM, Accession No. ML051670403, June 10, 2005

2. WCAP-1261 0-P-A & CENPD-404-P-A, Addendum 1-A, Optimized ZlRLOTM, Accession No. ML062080563, July 2006

3. Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, SERl Compliance with WCAP- 126 10-P-A & CENPD-404-P-A Addendum 1-A Optimized ZIRLO TM (Proprietary/Non-proprietary),LTR-NRC-07-1, Accession No. ML070100385, January 4, 2007

4. Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, SER Compliance with WCAP-126 10-P-A & CENPD-404-P-A Addendum 1-A Optimized ZIRLOTM (Proprietary/Non-proprietary)9,LTR-NRC-07-58, Accession No. ML073130556, November 6, 2007

5. Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, SER Compliance with WCAP-126 10-P-A & CENPD-404-P-A Addendum 1-A Optimized ZIRLO TM (Proprietary/Non-proprietary),LTR-NRC-07-58 Rev. 1, Accession No. ML080390451, February 5, 2008

6. Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, SER Compliance with WCAP- 126 10-P-A & CENPD-404-P-A Addendum 1-A Optimized ZIRLOTM (Proprietary/Non-proprietary),LTR-N RC-08-60, Accession No. ML090080380, December 30, 2008

7. Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, SER to RA-1 5-0020 Page 6 of 6 Compliance with WCAP-126 10-P-A & CENPD-404-P-A Addendum 1-A Optimized ZlRLOTM (Proprietary/Non-proprietary),LTR-NRC-10-43, Accession No. ML102140213, July 26, 2010

8. Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, SER Compliance with WCAP-126 10O-P-A & CENPD-404-P-A Addendum 1-A Optimized ZlRL OTM (Proprietaty/Non-proprietary),LTR-NRC-1 3-6, Accession No. ML13070A188, February 25, 2013

9. Letter from J. A. Gresham (Westinghouse) to USNRC (Document Control Desk),

Submittal of Responses to Draft RAIs and Revisions to Select Figuresin L TR-NRC-13-6 to Fulfill Conditions 6 and 7 of the Safety Evaluation for WCAP- 126 10-P-A & CENPD-404-P-A Addendum 1-A (Proprietary/Non-Proprietary),LTR-NRC-15-7, February 9, 2015 to RA-1 5-0020 Page 1 of 3 Enclosure 3 Technical Specification Markups for McGuire Nuclear Station, Units 1 and 2 to RA-1 5-0020 Page 2 of 3 Design Features 40 4.0 DESIGN FEATURES 4.1 Site Location The McGuire Nuclear Station site is located at latitude 35 degrees. 25 minutes. 59 seconds north and longitude 80 degrees, 56 minutes, 55 seconds west. The Universal Transverse Mercator Grid Coordinates are E 504, 669,256, and N 3, 920, 870. 471 The site is In northwestern Mecklenburg County. North Carolina, 17 miles north-northwest of Charlotte, North Carolina.

4.2 Reactor Core 4,2.1 Fu lA s m le * ......... ................. **"* *'S Si*S The reactor shall contain 193 fuel as.piblies Each assembly shall consist of a matrix of either *It! oi Zircalloytiel rods with an initial composition of natural or slightly enriched uranium dioxide (UOz) as fuel material. Limited substitutions Z* IO!, zirconium alloy or stainless steel filler rods for fuel

,rods. lcodance with approved applications of fuel rod configurations, may be

,};**ii'*i~q{ itrd. Fuel assemblies shall be limited to those fuel designs that have been i ................

Janalyzed with applicable NRC staff approved codes and methods and shown by tests or analyses to comply with all fuel safety design bases A limited number of lead test assemblies that have not completed representative testing may be placed in nonlimiting core regions.

4,2.2 Control R~od Assemblies The reactor core shall contain 53 control rod assemblies. The control material shall be silver indium cadmium (Unit 1) sitver indium cadmium and boron carbide (Unit 2) as approved by the NRC 4.3 Fuel Storage 4.3.1 Crtlt 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a, Fuel assemblies having a maximum norminal U-235 enrichment of 5 00 weight percent, b k,* 1.0 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9 1 of the UFSAR:

c. k~e < 0 95 if fully flooded with water borated to 800 ppm. which includes an allowance for uncertainties as descrnbed in Section 9 1 of the UFSAR, McGuire Units 1 and 2 40-1 Mc~ireUn~s 1and2 40-1Amendment Nos. 22$#L07 to RA-1 5-0020 Page 3 of 3 l' W^C)AP 12S1(bP A *VANTA(GE'* FI! kAi rmb Refeiree Co()i 11i WC.AP:*125~10! ,A 0.:D401-P+A, 52 AddJs1dPm I A 'O)*e Reporting Requirements5.

ZI'0~Jy2%)6 (Worst ighotu' ~ Propv :*a*r j 5 6 Reporting Require~ments _______________________

56 5 CORE PER *TING LIMITS REpORT (COIR) (continued)

14. DPC4NE-2009-P-A "Westinghouse Fuel Transition Report, (DPC Propnetary).

15 WCAP-12945-P-A. Volume 1 and Volumes 2-5, "Coda Qualification Document for Best-Estimate Loss of Coolant Analysis," (W Proprietary) 16 OPC-NE-1005P-A, "Duke Power Nuclear Design Methodology

Using CASMO-.4ISIMULATE-3 MOX," (DPG Proprietary).

17 DPC-NE-1 007-PA, =Conditional Exemption of the EOC M'rC Measurement Methodoiogy" (Duke and Westinghouse

<* Proprietary)

The COIR will contain the complete identification for each of the Technical Specifications referenced topical reports used to prepare the COLR (i.e., report number. Lt~le, revision number, report date or NRC SER date, and any supplements)

c. The core operating limits shall be determined such that all applicable limits (eg., fuel thermal mechanical limits, core thermal hydraulic limits Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SCM, transient analysis limits, and accident analysis llmils) of the safety analysis are met.

d The COLR, including any midcyde revisions or supplements. shall be provided upon issuance for each reload cycle to thie NRC.

56.6 Vetlto ~esHae alr e~r When a report is required by LCOs 3.6.10. "Annulus Ventilation System (AVS),"

or LCO 3.7.9, "Control Room Area Ventilation System (CRAVS)," a report shall be submitted within the following 30 days. The report shell outbrne the reason for the inoperability and the planned actions to return the systems to OPERABLE status 5 67 PAReor When a report is required by LCO 3.3.3. "Post Accident Monitoring (PAM)

Instrumentation," a report shall be submitted within the following 14 days. The report shall ou~tline the prepianned alternate method of monitoring, the cause of the Inoperability, and the plans and schedule for restoring the instrumenetaton channels of the Function to OPERABLE status (continued)

McGuire Units 1 end 2 5.6-4 Mo~ure ntsen2 56-4Amendment Nos a7w*268 to RA- 15-0020 Page 1 of 3 Enclosure 4 Technical Specification Markups for Catawba Nuclear Station, Units 1 and 2 to RA-1 5-0020 Page 2 of 3 Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site Location Catawba Nuclear Station is located in the north central portion of South Carolina approximately six miles north of Rock Hill and adjacent to Lake Wylie The station cantor is located at latitude 35 degrees, 3 minutes, 5 seconds north and longitude 81 degrees, 4 minutes, 10 seconds west. The corresponding Universal Transverse Mercator Coordinates are E 493, 660 and N 3, 678, 558, zone 17.

4.2 Reactor Core 4.2.1 Fuel Assem blies ..................... ......................................

The reactor shall contain 193 fuel z~Psemblies. Each assembly shall consist of a matrix of either Z4R*Q!I r ZircalloyPfuel rods with an initial compositon of natural or slightly enriched uranium dioxide (UOJ as fuel material." Limited substiutions* ZIR*O, zirconium alloy, or stainless steel filler rods for fuel

,,rods).j_ *6rd anca with approved applications of fuel rod configurations. may be

*-Sd Fuel assemblies shall be limited to those fuel designs that have been Janalyzed with applicable NRC staff approved codes and methods and shown by tests or analyses to comply with all fuel safety design bases A limited number of lead test assemblies that have not completed representative testing may be placed in nonhirniting core regions, A maximum of four lead assemblies containing mixed oxido fuel and M5TM cladding may be inserted into the Unit I or Unit 2 reactor core.I 4 2,2 Control Rod Assemblies The reactor core shall contain 53 control rod assemblies. The control material shall be silver indium cadmium and boron carbide as approved by the NRC.

4.3 Fuel Storage 43.1 Crtclt 4 3,1.1 The spent fuel storage racks are designed and shall be maintained with:

(continued)

Catawba Unds I and 2 4.0-1 Amendment Nos.

to RA- 15-0020 Page 3 of 3 R*>

(vest~ho.*seP~o*

t' ,;'i!995 **y)Reporting Requirements 5.6 Reporting ReguiremerI 5.65 CORE OPE *ATING LIMITS REPORT (COLR) (continued) 12 DPC-NE-2008-P-A, "Fuel Mechanical Reload Analysis Methodology Using TACO3" (DPC Proprietary).

13. WCAP-1 0054-P-A. =Westinghouse Small Break ECCS Evaluation Model Using the NOTRUMP Code" ()* Propnietary).

14. DPC-NE-2009-P-A, =Westinghouse Fuel Transition Reports (DPC Proprietary).

15. WCAP-1 2945-P-A. Volume 1 and Volumes 2-5, "Code Qualification Document for Best-Estimate Loss of Coolant IAnalysis" (V* Proprietary).

186 DPC-NE-1005P-A, "Duke Pour Nuclear Design Methodology Using CASMO-4/SIMULATE-3 MOX," (DPC Proprietary)

17. BAW-10231 P-A. 'COPERNIC Fuel Rod Design Computer Code,'

(Framatome ANP Proprietary).

18. DPC-NE-1IOO7-PA, 'Conditional Exemption of the EOC MTC iMeasurement Methodology" (Duke and Westinghouse Proprietary).

The COLR willl contain the complete identification for each of the Technical Specifications referenced topical reports used to prepare the COLR (Ike., report number, title, revision number, report date or NRC SER date, and any supplements).

c. The core operating hruits shall be determined such that all applicable limits (a g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) lImrits, nuclear limits such as SDM, b'ansient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

(continued)

Catawba Uffds I and 2 5.6-4 ,Amendment No*. 3*$