Text

Revision to Technical Specifications and 10 CFR 50.12 Exemption Request to Allow Use of Optimized ZIRLO
	ML16033A470
Person / Time
Site:	Wolf Creek
Issue date:	01/27/2016
From:	Mccoy J; Wolf Creek
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	ET 16-0001
	Download: ML16033A470 (27)
	v • d • e

W@ LF CREEK r'NUCLEAR OPERATING CORPORATION Jaime H. McCoy Vice President Engineering January 27, 2016 ET 16-0001 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Docket No. 50-482:

Revision to Technical Specifications and 10 CFR 50.12 Exemption Request to Allow Use of Optimized ZIRLO Gentlemen:

Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Wolf Creek Nuclear Operating Corporation (WCNOC) hereby requests an amendment to Renewed Facility Operating License No. NPF-42 for the Wolf Creek Generating Station (WCGS). The proposed amendment would modify the WCGS Technical Specifications (TS) to allow the use of Optimized ZIRLO TM as an approved fuel rod cladding. This change is consistent with the U.S. Nuclear Regulatory Commission (NRC) allowed use of Optimized ZIRLO TM fuel cladding material as documented in the Safety Evaluation included in Addendum 1-A to Westinghouse topical report WCAP-12610-P-A & CENPD-404-P-A,

'Optimized ZIRLO TM"'

TO support this change to allow the use of Optimized ZIRLO TM in accordance with 10 CFR 50.12, "Specific exemptions," WCNOC 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, "ECCS Evaluation. Models," to 10 CFR 50.

This exemption request relates solely to the specific type 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 ZIRLO TM has slightly different composition than Zircaloy or standard ZIRLO.

Attachment I provides a description of the proposed change and the supporting assessment of applicability and plant-specific variations. Attachment II provides the existing TS pages marked up to show the proposed change.

Attachment III provides revised (clean) TS pages.

Attachment IV provides proposed CORE OPERATING LIMITS REPORT (COLR) changes and is provided for information only. Attachment V provides the 10 CER 50.12 exemption request.

P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 I

An Equal Opportunity Employer M/F/HCNVET

ET 16-0001 Page 2 of 3 It has been determined that this amendment application does not involve a significant hazard consideration as determined per 10 CFR 50.92, "Issuance of amendment." Pursuant to 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," Section (b),

no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment.

The Plant Safety Review Committee reviewed this amendment application and exemption request. In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," a copy of this amendment application, with attachments, is being provided to the designated Kansas State official.

WCNOC requests approval of the proposed amendment prior to December 15, 2016 to support ordering new fuel in December 2016 for Cycle 23. It is anticipated that the license amendment, as approved, will be effective upon issuance and will be implemented within 90 days of NRC issuance.

This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4156, or Cynthia R. Hafenstine at (620) 364-4024.

Sincerely, Jamie H. McCoy J HM/rlt Attachments: I Description and Assessment II Proposed Technical Specification Changes (Markup)

IIl Revised Technical Specification Pages IV Proposed COLR Changes (For Information Only)

V 10 CFR 50.12 Exemption Request cc:

M. L. Dapas (NRC), w/a C. F. Lyon (NRC), w/a K. S. Steves (KDHE), w/a N. H. Taylor (NRC), w/a Senior Resident Inspector (NRC), w/a

ET 16-0001 Page 3 of 3 STATE OF KANSAS

)

COUNTY OF COFFEY

) S

)

Jamie H. McCoy, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By Jamie H.

cCoy Vice Pre ident Engineering r

SUBSCRIBED and sworn to before me this *, 1'+/-day of,,O L

, 2016.

I-*'°*-"-*_=My Appointment Expires Noa ubi Expiration Date

Attachment I to ET 16-0001 Page 1 of 11 DESCRIPTION AND ASSESSMENT 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination 4.4 Conclusion 5.0 ENVIRONMENTAL EVALUATION

6.0 REFERENCES

Attachment I to ET 16-0001 Page 2 of 11 DESCRIPTION AND ASSESSMENT 1.0

SUMMARY

DESCRIPTION Wolf Creek Nuclear Operating Corporation (WCNOC) proposes to revise the Wolf Creek Generating Station (WCGS) Technical Specifications (TS) to allow the use of Optimized ZIRLO TM fuel rod cladding material.

The current acceptable fuel rod cladding material is identified in TS 4.2.1, "Fuel Assemblies." The proposed change would revise TS 4.2.1 to add Optimized ZIRLO TM to the approved fuel rod cladding materials and correct the spelling of Zircaloy.

TS 5.6.5, "CORE OPERATING LIMITS REPORT (COLR)," is revised to add Westinghouse Electric Company LLC (Westinghouse) topical report WCAP-12610-P-A &

CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO TM," to the analytical methods used to determine the core operating limits previously reviewed and approved by the Nuclear Regulatory Commission (NRC).

Additionally, pursuant to 10 CFR 50.12, "Specific exemptions," WCNOC requests an exemption from the provisions of 10 CER 50.46, "Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors," and Appendix K, "ECCS Evaluation Models," to 10 CFR 50, to allow the use of Optimized ZIRLO TM fuel rod cladding in future core reload applications for WCGS. This exemption request is included as Attachment V.

Optimized ZIRLOTM was developed to meet the needs of longer operating cycles with increased fuel discharge burnup and fuel duty. Optimized ZIRLO TM fuel cladding is different from standard ZIRLO TM 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.

2.0 DETAILED DESCRIPTION The following revisions are proposed for the WCGS TS.

2.1 Technical Specification 4.2.1, "Fuel Assemblies" Revise TS 4.2.1 to include Optimized ZiRLO TM and correct the spelling of Zircaloy. The revised TS wording follows:

The reactor shall contain 193 fuel assemblies. Each assembly shall consist of a matrix of Zircaloy, ZIRLO, or Optimized ZIRLO TM clad fuel rods with an initial composition of natural or slightly enriched uranium dioxide (UO2) as fuel material. Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance 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.

Attachment I to ET 16-0001 Page 3 of 11 2.2 Technical Specification 5.6.5, "CORE OPERATING LIMITS REPORT (COLR)"

Revise TS 5.6.5b by adding:

12.

WCAP-1 261 0-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOTM.

Existing topical report reference 12 is renumbered to 13.

The addition of the registered sign "" and trademark notation "TM" is an editorial change that protects the intellectual property rights of Westinghouse without affecting the TS content requirements of 10 CFR 50.36.

3.0 TECHNICAL EVALUATION

Optimized ZIRLOTM is described in Westinghouse topical report WCAP-1261 0-P-A and CENPO-404-P-A, Addendum 1-A "Optimized ZIRLOTM," (Reference 1).

The NRC staff's Safety Evaluation (SE) for Optimized ZIRLOTM (Reference 2) 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 specified in the NRC's SE for WCAP-1 2610-P-A & CENPD-404-P-A, Addendum 1-A, are listed below.

WCNOC 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 ZIRLO TM 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 in Attachment V of 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 TM and Zircaloy-4 fuel analysis will continue to be met, except that the use of Optimized ZIRLO TM cladding in addition to standard ZIRLO TM and Zircaloy-4 cladding is now approved.

Attachment I to ET 16-0001 Page 4 of 11 RESPONSE: The fuel analysis of Optimized ZIRLO TM fuel rod cladding will continue to meet all conditions associated with approved methods. For WCNOC, 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 TM and Optimized ZIRLO TM 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 in approved methodologies will be made consistent with the approach accepted in WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOTM, July 2006. For WCNOC, 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 [Reference 3 [from the NRC SE))):

a.

Optimized ZIRLO TM LTA 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 ZIRLO TM 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 ZIRLO TM, 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 6.0 of this Attachment (References 3 through 9).

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 of 62 GWd/MTU, 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 ZIRLO TM cladding LTA programs to the NRC.

WCNOC has confirmed that the requirements of the condition and limitation have been met as they apply to WCGS.

Attachment I to ET 16-0001 Page 5 of 11

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

[Reference 3 [from the NRC SE))):

a.

Vogtle growth and creep data summary reports.

b.

Using the standard ZIRLO TM and Optimized ZIRLO TM 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 burnup for the Optimized ZIRLO TM 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 ZIRLO TM, 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 TM 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 through 9.

The data from three cycles of operation has been evaluated. The fuel rod creep models from fuel rod design codes have been confirmed to satisfactorily 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. WCNOC has confirmed that the requirements of this condition and limitation have been met as they apply to WCGS.

8.

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

a.

For the Westinghouse fuel design analyses:

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

ii.

Between BOL up to a radiation fluence of 3.0 x 1021 n/cm2 (E>IMeV),

pseudo-irradiated Optimized ZIRLO TM strength set equal to linear interpolation between the following two strength level points:

At zero fluence, strength of Optimized ZIRLO TM equal to measured strength of Optimized ZIRLO TM and at a fluence of 3.0 x 1021 n/cm2 (E>IMeV),

irradiated strength of standard ZIRLO TM at the fluence of 3.0 x 102* n/cm2 (E>1 MeV) minus 3 ksi.

Attachment I to ET 16-0001 Page 6 of 11 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. 0 x 1021 n/cm2 due to tin content) shall be decreased linearly such that the pseudo-irradiated Optimized ZIRLOTM strengths will saturate at the same properties as standard ZIRLO TM at 12 x 1021 n/cm2.

b.

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

RESPONSE: The fuel analysis of Optimized ZIRLO TM clad rods for WCGS will use the yield strength and ultimate tensile strength as modified per conditions and limitations 8.a.i., 8.a.ii.,

and 8.a.iii. until such time that the NRC completes its review and acceptance of the Optimized ZIRLO TM cladding yield strength model provided in Reference 10. WCNOC will confirm that the requirements of this condition and limitation will be met as it applies to WCGS during the normal reload design process.

WCGS uses a Westinghouse fuel design, and therefore, condition and limitation 8.b. does not apply.

9.

As discussed in response to RAI #21 (Reference 3 [from the NRC SE]), for plants introducing Optimized ZIRLO TM that are licensed with LOCBART or STRIKI N-Il and have a limiting PCT that occurs during blowdown or early reflood, the limiting LOCBART or STRIKIN-Il calculation will be rerun using the specified Optimized ZlRLO TM material properties. Although not a condition of approval, the NRC staff strongly recommends that, for future evaluations, Westinghouse update all computer models with Optimized ZIRLO TM specific material properties.

RESPONSE: WCGS is not licensed with LOCBART or STRIKIN-II, therefore, the condition and limitation does not apply.

10.

Due to the absence of high temperature oxidation data for Optimized ZIRLO TM, 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

For implementation of Optimized ZlRLO TM fuel cladding, the peak cladding temperature (PCT) calculated for the locked rotor event is assessed relative to the Westinghouse Optimized ZIRLO TM PCT limit.

For subsequent core reload designs, the calculated PCT will be reassessed as part of the normal reload design process.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include Technical Specifications (TSs) as part of the operating license. The TSs ensures the operational capability of structures, systems, and components that are required to protect the health and safety of the public. The U.S. Nuclear Regulatory Commission's (NRC's) requirements related to the content of the TSs are contained in Section 50.36 of the Title 10 of the Code of Federal Regulations (10 CFR 50.36) which requires that the TSs include items in the following specific categories: (1) safety limits, limiting safety system settings, and limiting

Attachment I to ET 16-0001 Page 7 of 11 control settings; (2) limiting conditions for operation; (3) surveillance requirements per 10 CFR 50.36(c)(3); (4) design features; and (5) administrative controls.

10 CFR 50.46 provides acceptance criteria for emergency core cooling systems (ECCS) for light-water nuclear power reactors.

Appendix K to 10 CFR Part 50 establishes the required and acceptable features of the ECCS evaluation models.

By letter dated June 10, 2005 (Reference 2), the NRC staff issued a safety evaluation approving Addendum I to Westinghouse topical report WCAP-1261 0-P-A & CENPD-404-P-A, "Optimized ZIRLOTM, wherein the NRC staff approved the use of Optimized ZIRLO TM as an acceptable fuel cladding material for Westinghouse and Combustion Engineering fuel designs.

Wolf Creek Nuclear Operating Corporation (WCNOC) evaluated the proposed changes to determine whether applicable regulations and requirements continue to be met.

This determination found that the proposed change to allow the use of Optimized ZIRLO TM 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." Attachment V of this request provides the basis and justification for exemption from these regulations.

4.2 Precedent The proposed changes to Wolf Creek Generating Station (WCGS) Technical Specification (TS) 4.2.1, "Fuel Assemblies," and TS 5.6.5, "CORE OPERATING LIMITS REPORT (COLR)," in this license amendment request are similar to the Seabrook Nuclear Plant request submitted June 15, 2013 (Reference 11). The NRC approved the requested changes in Amendment No. 139 to Facility Operating License No. NPF-86 on March 5, 2014 (Reference 12). The differences in the Seabrook Nuclear Plant request and this license amendment request are the TS section numbers and WCGS TS 5.6.5 does not include the date of the topical report or the associated TS.

Listing only the NRC-approved methodology by topical report number and title is consistent with Amendment No. 144 (Reference 13). Amendment No. 144 adopted TSTF-363, "Revise Topical Report References in ITS 5.6.5, COLR," and the NRC concluded in the safety evaluation that the proposed change to only list the NRC approved methodology by topical report number and title is acceptable. Technical Specification Task Force traveler TSTF-533-T, "Remove COLR and PTLR Revision and Date Relocation Provisions Added by TSTF-363, -408, and -419,"

added a Reviewer's Note to NUREG-1431 which states, "Licensees that have received prior NRC approval to relocate Topical Report revision numbers and dates to licensee control need only list the number and title of the Topical Report, and the COLR will contain the complete identification for each of the Technical Specification referenced Topical Reports used to prepare the COLR (i.e., report number, title, revision, date, and any supplements). See NRC ADAMS Accession No: MLl 10660285 for details [Reference 14]." TSTF-533-T was incorporated into Revision 4 of NUREG-1431.

Attachment I to ET 16-0001 Page 8 of 11 4.3 No Siqinificant Hazards Consideration Determination Wolf Creek Nuclear Operating Corporation (WCNOC) proposes to revise the Wolf Creek Generating Station (WCGS) 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 4.2.1, "Fuel Assemblies." The proposed change would revise TS 4.2.1 to add Optimized ZIRLOTM to the approved fuel rod cladding materials and correct the spelling of Zircaloy.

TS 5.6.5, "CORE OPERATING LIMITS REPORT (COLR)," is revised 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).

WCNOC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) 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 change would allow the use of Optimized ZIRLOTM clad nuclear fuel in the reactor.

The NRC approved topical report WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, addresses Optimized ZIRLO TM and demonstrates that Optimized ZIRLO TM 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 the 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?

Response: 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 & CENPD-404-P-A, Addendum 1-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 cladding 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 accident previously evaluated.

Attachment I to ET 16-0001 Page 9 of 11

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 ZIRLO TM are not significantly different from those of standard ZIRLO.

Optimized ZIRLO TM 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 ZIRLO TM material properties relative to standard ZIRLO could have some impact on the overall accident scenario, plant-specific LOCA analyses using Optimized ZIRLO TM properties will demonstrate that the acceptance criteria of 10 CFR 50.46 have been satisfied.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, WCNOC 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.

5.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a 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 change meets the eligibility criterion for categorical exclusion 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 change.

6.0 REFERENCES

1.

WCAP-1 261 0-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO TM, July 2006.

2.

NRC 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 ZIRLO TM,' (TAC No. MB8041)," June 10, 2005.

Attachment I to ET 16-0001 Page 10 of 11

3.

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

4.

Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance with WCAP-1261 0-P-A & CENPD-404-P-A, Addendum 1-A, 'Optimized ZIRLO TM'," 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 ZIRLO TM'," 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 ZIRLO'r M'," 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.

8.

Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance of WCAP-1 2610-P-A & CENPD-404-P-A Addendum 1-A, 'Optimized ZIRLO TM'," LTR-NRC-13-6, February 25, 2013.

9.

Letter from J. A. Gresham (Westinghouse) to USNRC, "Submittal of Responses to Draft RAIs and Revisions to Select Figures in LTR-NRC-1 3-6 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-1 5-7, February 9, 2015.

10.

Letter from J. A. Gresham (Westinghouse) to USNRC, "Submittal of Response to Condition 8.a of the Safety Evaluation Report (SER) on WCAP-1 2610-P-A & CENPD-404-P-A Addendum 1-A, 'Optimized ZI RLO TM' (Proprietary/Non-Proprietary)," LTR-NRC-1 5-84, September 29, 2015.

11.

Letter SBK-L-1 3070 from K. Walsh, NextEra Energy, to USRNC, "License Amendment Request 13-4 & 10 CFR 50.12 Exemption Request Optimized ZIRLO Fuel Rod Cladding,"

June 25, 2013. ADAMS Accession No. ML13183A056)

12.

NRC letter from J. G. Lamb, USNRC, to K. Walsh, NextEra Energy, "Seabrook Station, Unit No. 1 - Issuance of Amendment Regarding the Use of Optimized ZIRLOTM Fuel Rod Cladding Material (TAC NO. MF2410)," March 5, 2014.

ADAMS Accession No. ML13213A143.

13.

License Amendment No. 144, "Wolf Creek Generating Station - Issuance of Amendment RE: Relocation of Cycle Specific Parameters to the Core Operating Limits Report (TAC NO. MB1638)," March 28, 2002. ADAMS Accession No. ML020180190.

Attachment I to ET 16-0001 Page 11 of 11

14.

NRC letter from J. R. Jolicoeur to TSTF, "Implementation Of Travelers TSTF-363, Revision 0, "Revise Topical Report References in ITS 5.6.5, COLR [CORE OPERATING LIMITS REPORT]," TSTF-408, Revision 1, "Relocation of LTOP [LOW TEMPERATURE OVERPRESSURE PROTECTION] Enable Temperature and PORV [POWER-OPERATED RELIEF VALVE]

Lift Setting to the PTLR [PRESSURE-TEMPERATURE LIMITS REPORT]," AND TSTF-419, Revision 0, "Revise PTLR Definition and References in ISTS

[IMPROVED STANDARD TECHNICAL SPECIFICATION]

5.6.6, RCS

[REACTOR COOLANT SYSTEM] PTLR," August 4, 2011. ADAMS Accession No. ML110660285.

Attachment II to ET 16-0001 Page 1 of 3 ATTACHMENT II PROPOSED TECHNICAL SPECIFICATION CHANGES (MARKUP)

Attachment II to ET 16-0001 Page 2 of 3 Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site Location 4.1.1 The WCGS site is approximately 3.5 miles east of the John Redmond Reservoir in Coffey County, Kansas and is approximately 3.5 miles northeast of the town of Burlington.

4.2 Reactor Core 4.2.1 Fuel Assemblie._.ss/

The reactor shall contain 19 f/(uel assemblies. Each assembly shall consist of a matri of

~rc=!c;' r Z clIad fuel rods with an initial composition of natural or slightly enriched uranium dioxide (UO2) as fuel material. Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance 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.

4.2.2 Control Rod Assemblies The reactor core shall contain 53 control rod assemblies. The control rod material shall be silver indium cadmium or hafnium metal as approved by the NRC.

4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a.

Fuel assemblies having a maximum nominal U-235 enrichment of 5.0 weight percent. For fuel with enrichments greater than 4.6 nominal weight percent of U-235, the combination of enrichment and integral fuel burnable absorbers shall be sufficient so that the requirements of 4.3.1.1.b are met.

(continued)

Wolf Creek-Unit 1 4.0-1 WolfCrek -UnitI 40-1Amendment No. 423, 131

Attachment II to ET 16-0001 Page 3 of 3 Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

4.

WCAP-1 0216-P-A, "Relaxation of Constant Axial Offset Control -

FQ Surveillance Technical Specification."

5.

WCNOC Topical Report NSAG-007, "Reload Safety Evaluation Methodology for the Wolf Creek Generating Station."

6.

N RC Safety Evaluation Report dated March 30, 1993, for the "Revision to Technical Specification for Cycle 7."

7.

WCAP-16009-P-A, "Realistic Large Break LOCA Evaluation Methodology Using the Automated Statistical Treatment of Uncertainty Method (ASTRUM)."

8.

WCAP-1 6045-P-A, "Qualification of the Two-Dimensional Transport Code PARAGON."

9.

WCAP-1 6045-P-A, Addendum 1-A, "Qualification of the NEXUS Nuclear Data Methodology."

10.

WCAP 10965-P-A, "ANC: A Westinghouse Advanced Nodal Computer Code."

11.

WCAP-1 2610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report."

C.

~2.

WCAP-8745-P-A, "Design Bases for the Thermal Power AT and Thermal Overtemperature AT Trip Functions."

The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient 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.

12.

WCAP-12610-P-A&CENPD-404-P-A, Addendum 2:A: ~Optimized Zirlo~~j (continued)

Wolf Creek - Unit I 5.0-26 Amendment No. 123', 112, 1, 158,*

46

49.-O, 213

Attachment III to ET 16-0001 Page 1 of 3 ATTACHMENT III REVISED TECHNICAL SPECIFICATION PAGES

Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site Location 4.1.1 The WCGS site is approximately 3.5 miles east of the John Redmond Reservoir in Coffey County, Kansas and is approximately 3.5 miles northeast of the town of Burlington.

4.2 Reactor Core 4.2.1 Fuel Assemblies The reactor shall contain 193 fuel assemblies. Each assembly shall consist of a matrix of Zircaloy, ZIRLO, or Optimized ZIRLO TM clad fuel rods with an initial composition of natural or slightly enriched uranium dioxide (UO2) as fuel material.

Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance 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.

4.2.2 Control Rod Assemblies The reactor core shall contain 53 control rod assemblies. The control rod material shall be silver indium cadmium or hafnium metal as approved by the NRC.

4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a.

Fuel assemblies having a maximum nominal U-235 enrichment of 5.0 weight percent. For fuel with enrichments greater than 4.6 nominal weight percent of U-235, the combination of enrichment and integral fuel burnable absorbers shall be sufficient so that the requirements of 4.3.1.1.b are met.

(continued)

Wolf Creek-Unit 1 4.0-1 Wolf reek-Unt I.0-1Amendment No. 423-,43---

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

4.

WCAP-1 021 6-P-A, "Relaxation of Constant Axial Offset Control -

EQ Surveillance Technical Specification."

5.

WCNOC Topical Report NSAG-007, "Reload Safety Evaluation Methodology for the Wolf Creek Generating Station."

6.

NRC Safety Evaluation Report dated March 30, 1993, for the "Revision to Technical Specification for Cycle 7."

7.

WCAP-1 6009-P-A, "Realistic Large Break LOCA Evaluation Methodology Using the Automated Statistical Treatment of Uncertainty Method (ASTRUM)."

8.

WCAP-1 6045-P-A, "Qualification of the Two-Dimensional Transport Code PARAGON."

9.

WCAP-1 6045-P-A, Addendum 1-A, "Qualification of the NEXUS Nuclear Data Methodology."

10.

WCAP 10965-P-A, "ANC: A Westinghouse Advanced Nodal Computer Code."

11.

WCAP-1 2610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report."

12.

WCAP-1 2610-P-A &.CENPD-404-P-A, Addendum 1-A, "Optimized ZlRLOTM."

13.

WCAP-8745-P-A, "Design Bases for the Thermal Power AT and Thermal Overtemperature AT Trip Functions."

c.

The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient 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)

Wolf Creek-Unit 1 5.0-26 Amendment No. 123, 112,111,158, 164,179, 209v,

213,

Attachment IV to ET 16-0001 Page 1 of 2 ATTACHMENT IV PROPOSED COLR CHANGES (FOR INFORMATION ONLY)

Attachment IV to ET 16-0001 Page 2 of 2CR oE CLEA*R OPERATINGCOORTN Wolf Creek Generating Station Cycle 21 Core Operating Limits Report Revision 1

7.

WCAP-1 6009-P-A, "Realistic Large Break LOCA Evaluation Methodoiogy Using Automated Statistical Treatment of Uncertainty Method (ASTRUM),"

Revision 0, January 2005.

NRC letter dated November 5, 2004,"Final Safety Evaluation for WCAP-16009-P, Revision 0, "Realistic Large Break LOCA Evaluation Methodology Using Automated Statistical Treatment of Uncertainty Method (ASTRUM)"

(TAC NO. MB9483)."

8.

WCAP-1 6045-P-A, "Qualification of the Two-Dimensional Transport Code PARAGON," August 2004.

NRC Safety Evaluation dated March 18, 2004, "Final Safety Evaluation for Westinghouse Topical Report WCAP-1 6045-P, Revision 0, "Qualification of the Two-Dimensional Transport Code PARAGON."

9.

WCAP-1 6045-P-A, Addendum 1-A, "Qualification of the NEXUS Nuclear Data Methodology," August 2007.

NRC Safety Evaluation dated February 23, 2007, "Final Safety Evaluation for Westinghouse Electric Company (Westinghouse) Topical Report (TR) WOAP-16045-P-A, Addendum 1, "Qualification of the NEXUS Nuclear Data Methodology" (TAC NO. MC9606)."

10. WCAP 10965-P-A, "ANC: A Westinghouse Advanced Nodal Computer Code,"

September 1986.

NRC letter dated June 23, 1986, "Acceptance for Referencing of Topical Report WCAP 10965-P and WCAP 10966-NP."

11. WCAP-1 2610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report," April 1995.

NRC Safety Evaluation Reports dated July 1, 1991, "Acceptance for Referencing of Topical Report WCAP-1 2610, 'VANTAGE+ Fuel Assembly Reference Core Report' (TAC NO. 77258)."

NRC Safety Evaluation Report dated September 15, 1994, "Acceptance for Referencing of Topical Report WCAP-12610, Appendix B, Addendum 1,

'Extended Burnup Fuel Design Methodology and ZIRLO Fuel Performance

.+.2..Models' (TAC NO. M86416)."

WCAP-8745-P-A, "Design Bases for the Thermal Overpower AT and Thermal gvreprtr AT Trip Function." September 1986.

N~RC Safety Evaluation Report dated April 17, 1986, "Acceptance for

~Referencing of Licensing Topical Report WCAP-8745(P)/8746(NP), 'Design

~Bases for the Thermal Overpower AT and Thermal Overtemperature AT Trip Page 16 of 16

Attachment V to ET 16-0001 Page 1 of 5 ATTACHMENT V 10 CFR 50.12 Exemption Request

Attachment V to ET 16-0001 Page 2 of 5 1.0 Purpose Wolf Creek Nuclear Operating Corporation (WCNOC) requests an exemption from the provisions of 10 CER 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 ZIRLO TM High Performance Fuel Cladding Material in future core reload applications for Wolf Creek Generating Station (WCGS). The regulations 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 Cladding Material. Concurrently, Appendix K to 10 CFR Part 50, paragraph IA.5, requires the Baker-Just equation to be used to predict the rates of energy release, hydrogen generation, and cladding oxidation from the metal-water reaction in the core. The Baker-Just equation assumes the use of a zirconium alloy other than Optimized ZIRLOTM material.

Therefore, an exemption is required from both 10 CFR 50.46 and 10 CFR Part 50 Appendix K to support the use of Optimized ZIRLO TM fuel rod cladding at WCGS. This exemption request relates solely to the specific cladding material identified in these regulations (i.e., fuel rods with Zircaloy or ZIRLO cladding) and will provide for the application of 10 CFR 50.46 and 10 CFR Part 50, Appendix K acceptance criteria to fuel assembly designs utilizing Optimized ZIRLO TM fuel rod cladding at WCGS.

2.0

Background

As the nuclear industry pursues longer operating cycles, with increased fuel discharge burnup and fuel duty, the corrosion performance requirements for nuclear fuel cladding become more demanding. Optimized ZIRLOTM material was developed to be more resistant to accelerated corrosion, due to abnormal chemistry conditions, than ZIRLO, while retaining its mechanical strength benefits. 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 the temperature feedback effects, provides additional margin to the fuel rod internal pressure design limit.

Technical Specification (TS) changes for WCGS are required to allow the use of Optimized ZIRLOTM fuel rod cladding for core reload applications.

The request for these changes is provided in Attachment I to this submittal.

3.0 Technical Justification of Acceptability Westinghouse Electric Company LLC (Westinghouse) topical report WCAP-12610-P-A &

CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOTM," (Reference 1), provides the details and results of tests comparing Optimized ZIRLO TM material and standard ZIRLO material (as well as the material properties to be used in various models and methodologies when analyzing Optimized ZIRLO TM 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 that WCNOC request an exemption from 10 CER 50.46 and 10 CFR Part 50, Appendix K (which is being requested via this letter) before implementing Optimized ZIRLO TM at WCGS. Westinghouse has provided the NRC with information related to test data and models (References 3 through 10) to address conditions and limitations 6, 7, and 8a.

Condition and limitation 9 is not applicable since WCGS is not licensed to use LOCBART or STRIKIN-II codes. The remaining conditions and limitations are addressed with changes to the WCGS TS and the evaluations that are required to support core reload activities. Since plant-

Attachment V to ET 16-0001 Page 3 of 5 specific TS changes are required prior to utilizing Optimized ZIRLO TM fuel rod cladding, no additional commitments are necessary to support NRC approval of this exemption request.

Future reload evaluations will ensure that acceptance criteria are met for the insertion of assemblies composed of fuel rods clad with Optimized ZIRLO TM material.

These fuel assemblies will be evaluated using NRC-approved methods and models to address the use of Optimized ZIRLO TM fuel rod cladding in the core.

4.0 Justification of Exemption 10 CFR 50.12, "Specific exemptions," specifies 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; and (2) the Commission will not consider granting an exemption unless special circumstances are present.

The requested exemption to allow the use of Optimized ZIRLO TM fuel rod cladding material in addition to Zircaloy or ZIRLO material for core reload applications at WCGS satisfies these criteria as described below.

Condition (1)

a.

This exemption 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 (i.e., fuel rods with Zircaloy or ZIRLO cladding) in 10 CFR 50.46 and implied in 10 CFR 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.

Note that WCNOC is not seeking an exemption from the acceptance and analytical criteria of 10 CFR 50.46 and 10 CFR Part.50, Appendix K. The intent of this request is solely to allow the use of criteria set forth in these regulations for application to the Optimized ZIRLO TM fuel rod cladding material.

b.

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 ZIRLO TM material. Fuel assemblies using Optimized ZIRLO TM 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 WCGS 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.

Attachment V to ET 16-0001 Page 4 of 5

c.

This exemption is consistent with common defense and security As noted above, this exemption request is only to allow the application of the aforementioned regulations to an improved fuel rod cladding material. 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 ZIRLO TM fuel rod cladding in the WCGS core will not affect plant operations and is consistent with common defense and security.

Condition (2)

Special circumstances support the issuance of an exemption 10 CER 50.12(a)(2) specifies that the NRC will not consider granting an exemption to the regulations unless special circumstances are present. This exemption request meets the special circumstances criteria of 10 CFR 50.12(a)(2)(ii), "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." For WCGS, 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 ZIRLO TM material and standard ZIRLO material, the current ECCS analysis approach remains applicable.

Westinghouse will perform an evaluation of the WCGS core using loss-of-coolant accident (LOCA) methods approved for the site to ensure that assemblies with Optimized ZIRLO TM fuel rod cladding material meet the 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 ZIRLO TM alloy. Due to the similarities in the composition of the Optimized ZIRLO TM 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 Th~e 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 ZIRLO cladding. 10 CFR 50.46 and 10 CER Part 50, Appendix K do not apply to the proposed use of Optimized ZIRLO TM fuel rod cladding material since Optimized ZIRLO TM 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 TM fuel rod cladding at WCGS.

In order to support the use of Optimized ZIRLO TM fuel rod cladding material at WCGS, 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.

A A

Attachment V to ET 16-0001 Page 5 of 5 6.0 References

1.

WCAP-1261 0-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO TM, July 2006.

2.

NRC 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 ZIRLO TM,' (TAC No. MB8041)," 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 ZIRLO TM'," 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 ZIRLO TM',' LTR-NRC-07-58, November 6, 2007.

5.

Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance with WCAP-1261 0-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-1 2610-P-A

& CENPD-404-P-A Addendum 1-A,

'Optimized ZIRLO TM'," LTR-NRC-08-60, December 30, 2008.

7.

Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance of WCAP-1 2610-P-A & CENPD-404-P-A Addendum 1-A, 'Optimized ZIRLO TM'," LTR-NRC-10-43, July 26, 2010.

8.

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-13-6, 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 Figures in LTR-NRC-13-6 to Fulfill Conditions 6 and 7 of the Safety Evaluation for WCAP-1 2610-P-A & CENPD-404-P-A Addendum 1-A (Proprietary/Non-Proprietary)," LTR-NRC-15-7, February 9, 2015.

10.

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

"Submittal of Response to Condition 8.a of the Safety Evaluation Report (SER) on WCAP-12610-P-A & CENPD-404-PA Addendum 1-A, Optimized ZIRLO TM' (Proprietary/Non-Proprietary)," LTR-NRC-15-84, September 29, 2015.