Text

License Amendment Request and 10 CFR 50.12 Exemption Request for the Use of Optimized ZIRLO Fuel Rod Cladding
	ML16055A149
Person / Time
Site:	Byron, Braidwood
Issue date:	02/23/2016
From:	Simpson P; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RS-16-034
	Download: ML16055A149 (36)
	v • d • e

4300 Winfield Road Warrenville, IL 60555 Amow ExeLon Generation 630 657 2000 Office RS-16-034 February 23, 2016 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 10 CFR 50.90 10 CFR 50.12 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and 50-455

Subject:

License Amendment Request and 10 CFR 50.12 Exemption Request for the Use of Optimized ZIRLOTM Fuel Rod Cladding In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests an amendment to Renewed Facility Operating License Nos. NPF-72 and NPF-77 for Braidwood Station, Units 1 and 2 (Braidwood), and Renewed Facility Operating License Nos. NPF-37 and NPF-66 for Byron Station, Units 1 and 2 (Byron). This amendment request proposes to revise Braidwood and Byron Technical Specifications (TS) 4.2.1, "Reactor Core, Fuel Assemblies," to add Optimized ZIRLOTM as an approved fuel rod cladding material. This change is consistent with the U. S. Nuclear Regulatory Commission (NRC) allowed use of Optimized ZIRLOTM 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 ZIRLOTM." EGC proposes to revise Braidwood and Byron TS 5.6.5.b, "Core Operating Limits Report (COLR)," to add the Westinghouse topical reports for Optimized ZIRLOTM and ZIRLO° (i.e., WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, and WCAP-12610-P-A, respectively) to the current list of NRC approved analytical methods used to determine the core operating limits. In addition, a non-technical change to S 5.6.5.b is proposed in the form of a revision to the title of Reference 11.

To support the change to allow the use of Optimized ZIRLOTM, in accordance with 10 CFR 50.12, EGC is also requesting an exemption from certain requirements of 10 CFR 50.46, "Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors," and Appendix K to 10 CFR Part 50, "ECCS Evaluation Models." This exemption request, a requirement of the first condition of the NRC Safety Evaluation for WCAP-12610-P-A &

CENPD-404-P-A, Addendum 1-A, relates solely to the specific types of cladding material specified in these regulations for use in light water reactors. As written, the regulations presume use of either Zircaloy or ZIRLO" fuel rod cladding. The exemption is required since Optimized ZIRLOTM has a slightly different composition than Zircaloy or standard ZIRLO".

February 23, 2016 U. S. Nuclear Regulatory Commission Page 2 The attached request is subdivided as follows:

Attachment 1 provides a description and evaluation of the proposed changes.

Attachment 2 provides the Exemption Request.

Attachment 3 provides the markup of the affected TS pages for Braidwood.

Attachment 4 provides the markup of the affected TS pages for Byron.

The proposed changes have been reviewed by the Braidwood and Byron Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program.

EGC requests NRC approval of the proposed license amendment request and associated exemption request by February 28, 2017, in support of the core designs for the Braidwood, Unit 1, Cycle 21 core reload, which is scheduled to begin in the spring of 2018. Once approved, the amendments will be implemented within 60 days.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),

EGC is notifying the State of Illinois of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

There are no regulatory commitments contained within this letter. Should you have any questions concerning this letter, please contact Ms. Lisa A. Simpson at (630) 657-2815.

1 declare under penalty of perjury that the foregoing is true and correct. Executed on the 23rd day of February 2016.

R

ectfully, Patrick R. Simpson Manager Licensing Fxelon Generation Company, 1 1 Attachments:

1) Evaluation of Proposed Changes

2) Exemption Request

3) Markup of Technical Specifications Pages Braidwood Station, Units 1 and 2

4) Markup of Technical Specifications Pages Byron Station, Units 1 and 2

February 23, 2016 U. S. Nuclear Regulatory Commission Page 3 cc:

NRC Regional Administrator, Region III NRC Senior Resident Inspector, Braidwood Station NRC Senior Resident Inspector, Byron Station Illinois Emergency Management Agency Division of Nuclear Safety

ATTACHMENT 1 Evaluation of Proposed Changes

Subject:

License Amendment Request for Optimized ZIRLOTm Fuel Rod Cladding 1.0

SUMMARY

DESCRIPTION 2.0

DETAILED DESCRIPTION 2.1

TS 4.2.1, "Reactor Core, Fuel Assemblies" 2.2

TS 5.6.5.b, "Core Operating Limits Report (COLR)"

==3.0

TECHNICAL EVALUATION==

3.1

Background Information 3.2

Technical Justification of Acceptability

==4.0

REGULATORY EVALUATION==

4.1

Applicable Regulatory Requirements/Criteria 4.2

Precedent 4.3

No Significant Hazards Consideration 4.4

Conclusions

==5.0

ENVIRONMENTAL CONSIDERATION==

6.0 REFERENCES

Page 1 of 17

ATTACHMENT 1 Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Renewed Facility Operating License Nos. NPF-72 and NPF-77 for Braidwood Station, Units 1 and 2 (Braidwood), and Renewed Facility Operating License Nos. NPF-37 and NPF-66 for Byron Station, Units 1 and 2 (Byron).

Exelon Generation Company, LLC, (EGC) proposes to revise the Braidwood and Byron Technical Specifications (TS) to allow the use of Optimized ZI RLOTM fuel rod cladding material.

The current acceptable fuel rod cladding materials are identified in Braidwood and Byron TS 4.2.1, "Reactor Core, Fuel Assemblies." The proposed change revises Braidwood and Byron TS 4.2.1 to add Optimized ZIRLOTM as an approved fuel rod cladding material. This change is consistent with the U. S. Nuclear Regulatory Commission (NRC) allowed use of Optimized ZIRLOTM fuel cladding material as documented in the Safety Evaluation included in Addendum 1-A to Westinghouse Electric Company LLC (Westinghouse) topical report WCAP-12610-P-A & CENPD-404-P-A, "Optimized ZIRLOTM,, (Reference 2).

EGC proposes to revise Braidwood and Byron TS 5.6.5.b, "Core Operating Limits Report (COLR)," to add Westinghouse topical report WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOTM,,, (Reference 1) to the current list of NRC approved analytical methods used to determine the core operating limits. EGC proposes to add the Westinghouse topical report for ZIRLO°, WCAP-12610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report," (Reference 14) to the documents listed in TS 5.6.5.b as this WCAP was previously approved by the NRC for Braidwood and Byron by NRC letter dated December 19, 1995 (Reference 15). EGC is also proposing a non-technical change to TS 5.6.5.b in the form of a revision to the title of Reference 11 to correct a grammatical error (i.e., replacing a semicolon with a period) introduced in Amendments 174 and 181 to Braidwood and Byron, respectively, dated February 7, 2014 (Reference 16).

In addition to the proposed TS changes, in accordance with 10 CFR 50.12, EGC requests an exemption from certain requirements of 10 CFR 50.46, "Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors," and Appendix K to 10 CFR Part 50, "ECCS Evaluation Models," to allow the use of Optimized ZIRLOTM fuel rod cladding in future core reload applications for Braidwood and Byron. This exemption request, a requirement of the first condition of the NRC Safety Evaluation for WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A (Reference 2), 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 ZIHL03 fuel rod cladding. The exemption is required since Optimized ZIRLOTM has a slightly different composition than Zircaloy or standard ZIRLOO. The exemption request is provided in Attachment 2 to this submittal.

EGC currently plans to use Optimized ZIRLOTM as the fuel rod cladding material for Braidwood and Byron reloads starting with the new fuel introduced for Braidwood, Unit 1, Cycle 21, which is scheduled to begin in the spring of 2018. Approval of this proposed license amendment request and associated exemption request is requested by February 28, 2017, to support the implementation activities, including the core designs. Once approved, the amendments will be implemented within 60 days.

Page 2 of 17

ATTACHMENT 1 Evaluation of Proposed Changes 2.0

DETAILED DESCRIPTION A specific description of each change is provided below. In addition, TS markups are provided in Attachments 3 and 4 of this document for Braidwood and Byron, respectively.

2.1

TS 4.2.1, "Reactor Core, Fuel Assemblies" Braidwood and Byron TS 4.2.1, "Reactor Core, Fuel Assemblies," would be revised to add Optimized ZI RLOTM as an approved fuel rod cladding material.

Current Braidwood TS 4.2.1 The reactor shall contain 193 fuel assemblies. Each assembly, with exceptions as noted below, shall consist of a matrix of Zircaloy or ZI RLO 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 or vacancies 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.

Up to 8 AREVA NP Advanced Mark-BW(A) fuel assemblies containing M5 alloy may be placed in nonlimiting Unit 1 core regions for evaluation during Cycles 15, 16, and 17.

Proposed Braidwood TS 4.2.1 (with changes in bold)

The reactor shall contain 193 fuel assemblies. Each assembly, with exceptions as noted below, shall consist of a matrix of Zircaloy, ZIRLO°, or Optimized ZIRLOTM 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 or vacancies 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.

Page 3 of 17

ATTACHMENT 1 Evaluation of Proposed Changes Up to 8 AREVA NP Advanced Mark-BW(A) fuel assemblies containing M5 alloy may be placed in nonlimiting Unit 1 core regions for evaluation during Cycles 15, 16, and 17.

Current Bvron TS 4.2.1 The reactor shall contain 193 fuel assemblies. Each assembly shall consist of a matrix of Zircaloy or ZIRLO 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 or vacancies 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.

Proposed Byron TS 4.2.1 (with changes in bold)

The reactor shall contain 193 fuel assemblies. Each assembly shall consist of a matrix of Zircaloy, ZIRLO°, or Optimized ZIRLOTM 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 or vacancies 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.

2.2

TS 5.6.5.b, "Core Operating Limits Report (COLR)"

Braidwood and Byron TS 5.6.5.b, "Core Operating Limits Report (COLR)," currently include a list of 11 documents that define the NRC approved analytical methods used to determine the core operating limits. The proposed revision to Braidwood and Byron TS 5.6.5.b would add the Westinghouse topical reports for Optimized ZIRLOTM and ZIRLO° (i.e., Addendum 1-A to WCAP-12610-P-A & CENPD-404-P-A (Reference 1) and WCAP-12610-P-A (Reference 14)) as TS 5.6.5.b, References 13 and 12, respectively.

In addition, Braidwood and Byron TS 5.6.5.b would also be revised with a non-technical change to revise the title of Reference 11 (i.e., replacing a semicolon with a period).

Page 4 of 17

ATTACHMENT 1 Evaluation of Proposed Changes Current Braidwood and Bvron TS 5.6.5.b The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

11.

WCAP-14565-P-A, "VIPRE-01 Modeling and Qualification for Pressurized Water Reactor Non-LOCA Thermal-Hydraulic Safety Analysis," October 1999; Proposed Braidwood and Byron TS 5.6.5.b (with changes in bold)

The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

11.

WCAP-14565-P-A, "VIPRE-01 Modeling and Qualification for Pressurized Water Reactor Non-LOCA Thermal-Hydraulic Safety Analysis," October 1999.

12.

WCAP-12610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report," April 1995. (Westinghouse Proprietary).

13.

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

==3.0

TECHNICAL EVALUATION==

3.1

Background Information 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 have become more demanding. Optimized ZIRLOTM material was developed to meet these needs and provide 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.

EGC currently plans to use Optimized ZIRLOTM as the fuel rod cladding material for Braidwood and Byron reloads starting with the new fuel introduced for Braidwood, Unit 1, Cycle 21, which is scheduled to begin in the spring of 2018.

Page 5 of 17

ATTACHMENT 1 Evaluation of Proposed Changes 3.2

Technical Justification of Acceptability Westinghouse topical report WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, (Reference 1) provides the details and results of testing of Optimized ZIRLOTM material compared to standard ZIRLOO' material as well as the material properties to be used in various models and methodologies when analyzing Optimized ZIRLOTM fuel rod cladding.

The NRC Safety Evaluation for WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, (Reference 2) contains ten conditions and limitations. The first condition requires an exemption from 10 CFR 50.46 and 10 CFR Part 50, Appendix K, which is provided in to this submittal. 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. Conditions and limitations 8.b and 9 do not apply because Braidwood and Byron do not have a Combustion Engineering (CE) fuel design and are not licensed with LOCBART or STRIKIN-11. The remaining conditions and limitations will be addressed in the Braidwood and Byron TS changes and evaluations required to support core reload activities. Since plant-specific TS changes are required prior to utilizing Optimized ZIRLOTM fuel rod cladding, no new commitments are necessary to support NRC approval of this request.

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

The ten conditions and limitations provided in the NRC Safety Evaluation for WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, (Reference 2) are listed below.

EGC 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 Appendix K to 10 CFR 50 is provided in Attachment 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 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.

Page 6 of 17

ATTACHMENT 1 Evaluation of Proposed Changes 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 Safety Evaluation approvals for methodologies used for standard ZI RLO° and Zircaloy-4 fuel analysis will continue to be met, except that the use of Optimized ZIRLOTM cladding in addition to standard ZIRLO" and Zircaloy-4 cladding is now approved.

RESPONSE: The fuel analysis of Optimized ZIRLOTM fuel rod cladding will continue to meet all conditions associated with approved methods. For Braidwood and Byron, this is a current requirement, and confirmation of these conditions is required as part of the normal reload design process.

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

RESPONSE: The application of ZIRLO and Optimized ZIRLOTM cladding in approved methodologies will be made consistent with the approach accepted in WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A (Reference 1). For Braidwood and Byron, this is a current requirement, and confirmation of these conditions is required as part of the normal reload design process.

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

a. Optimized ZIRLOTM LTA data from Byron, Calvert Cliffs, Catawba, and Millstone.

i.

Visual ii.

Oxidation of fuel rods iii.

Profilometry iv.

Fuel rod length V.

Fuel assembly length

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

Confirmation of the approved models' applicability up through the projected end of cycle burnup for the Optimized ZIRLOTM fuel rods must be completed prior to their initial batch loading and prior to the startup of subsequent cycles. For example, prior to the first batch application of Optimized ZIRLOTM, sufficient LTA data may only be available to confirm the models' applicability up through 45 GWd/MTU. In this example, the licensee would need to confirm the models up through the end of the initial cycle. Subsequently, the licensee would need to confirm the models, based Page 7 of 17

ATTACHMENT 1 Evaluation of Proposed Changes upon the latest LTA data, prior to re-inserting the Optimized ZI RLO' M fuel rods in future cycles. Based upon the LTA schedule, it is expected that this issue may only be applicable to the first few batch implementations since sufficient LTA data up through the burnup limit should be available within a few years.

RESPONSE: Westinghouse has provided the NRC with information related to test data and models in the following letters:

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 ZI RLOTM' (Proprietary/Non-proprietary),"

LTR-NRC-07-1, January 4, 2007 (Reference 3).

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 ZIRLOTM' (Proprietary/Non-proprietary),"

LTR-NRC-07-58, November 6, 2007 (Reference 4).

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 ZI RLOTM' (Proprietary/Non-proprietary),"

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

Letter from J. A. Gresham (Westinghouse) to U. S. Nuclear Regulatory Commission, "SER Compliance of WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A'Optimized ZIRLOTM' (Proprietary/Non-proprietary),"

LTR-NRC-08-60, December 30, 2008 (Reference 6).

Letter from J. A. Gresham (Westinghouse) to U. S. Nuclear Regulatory Commission, "SER Compliance of WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A 'Optimized ZIRLOTM' (Proprietary/Non-proprietary),"

LTR-NRC-10-43, July 26, 2010 (Reference 7).

Letter from James A. Gresham (Westinghouse) to U. S. Nuclear Regulatory Commission, "SER Compliance of WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A 'Optimized ZIRLOTM' (Proprietary/Non-proprietary),"

LTR-NRC-13-6, February 25, 2013 (Reference 8).

Letter from James A. Gresham (Westinghouse) to U. S. Nuclear Regulatory Commission, "Submittal of Responses to Draft RAls and Revisions to Select Figures in LTR-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 (Reference 9).

Page 8 of 17

ATTACHMENT 1 Evaluation of Proposed Changes 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 ZIRLOTM cladding LTA programs to the NRC. Exelon has confirmed that the requirements of this condition have been met as it applies to Braidwood and Byron.

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

a. Vogtle growth and creep data summary reports.

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

Confirmation of the approved models' applicability up through the projected end of cycle burnup for the Optimized ZIRLOTM fuel rods must be completed prior to their initial batch loading and prior to the startup of subsequent cycles. For example, prior to the first batch application of Optimized ZIRLOTM, sufficient LTA 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 following letters:

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 ZIRLOTM' (Proprietary/Non-proprietary),"

LTR-NRC-07-1, January 4, 2007 (Reference 3).

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 ZIRLOTM, (Proprietary/Non-proprietary),"

LTR-NRC-07-58, November 6, 2007 (Reference 4).

Page 9 of 17

ATTACHMENT 1 Evaluation of Proposed Changes 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 ZI RLO' M' (Proprietary/Non-proprietary),"

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

Letter from J. A. Gresham (Westinghouse) to U. S. Nuclear Regulatory Commission, "SER Compliance of WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A 'Optimized ZIRLOTM, (Proprietary/Non-proprietary),"

LTR-NRC-08-60, December 30, 2008 (Reference 6).

Letter from J. A. Gresham (Westinghouse) to U. S. Nuclear Regulatory Commission, "SER Compliance of WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A 'Optimized ZIRLOTM, (Proprietary/Non-proprietary),"

LTR-NRC-10-43, July 26, 2010 (Reference 7).

Letter from James A. Gresham (Westinghouse) to U. S. Nuclear Regulatory Commission, "SER Compliance of WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A'Optimized ZIRLOTM, (Proprietary/Non-proprietary),"

LTR-NRC-13-6, February 25, 2013 (Reference 8).

Letter from James A. Gresham (Westinghouse) to U. S. Nuclear Regulatory Commission, "Submittal of Responses to Draft RAls and Revisions to Select Figures in LTR-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 (Reference 9).

The data from three cycles of operation has been evaluated. The fuel rod creep models from fuel rod design codes have been used to predict the growth and creep performance and have confirmed the models applicability to predict grown and creep performance satisfactorily. 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. Exelon has confirmed that the requirements of this condition have been met as it applies to Braidwood and Byron.

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

Page 10 of 17

ATTACHMENT 1 Evaluation of Proposed Changes

a. For the Westinghouse fuel design analyses:

The measured, unirradiated Optimized ZIRLOTM strengths shall be used for Beginning of Life (BOL) analyses.

Between BOL up to a radiation fluence of 3.0 x 1021 n/cm2 (E>1 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 ZIRLOTM and at a fluence of 3.0 x 1021 n/cm2 (E>1 MeV),

irradiated strength of standard ZIRLO°at a fluence of 3.0 x 1021 n/cm2 (E>1 MeV) minus 3 ksi.

iii.

During subsequent irradiation from 3.0 x 102i 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° at 12 x 1021 n/cm2.

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: Braidwood and Byron use a Westinghouse fuel design; therefore, condition 8.b does not apply.

The fuel analysis of Optimized ZIRLOTM clad rods for Braidwood and Byron will use the yield strength and ultimate tensile strength as modified per Conditions 8.a.i, 8.a.ii, and 8.a.iii until such time that irradiated data for Optimized ZIRLOTM cladding strengths have been collected and provided to the NRC. Exelon will confirm that the requirements of this condition will be met as it applies to Braidwood and Byron during the normal reload process.

Westinghouse has provided the NRC with information related to irradiated data for Optimized ZIRLOTM cladding strengths in the following letter:

Letter from James A. Gresham (Westinghouse) to U. S. Nuclear Regulatory Commission, "Submittal of Response to Condition 8.a of the Safety Evaluation Report (SER) on WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A, 'Optimized ZIRLOTM,' (Proprietary/Non-Proprietary),"

LTR-NRC-15-84, September 29, 2015 (Reference 10).

9. As discussed in response to RAI #21, for plants introducing Optimized ZIRLOTM that are licensed with LOCBART or STRIKIN-II and have a limiting PCT that occurs during blowdown or early reflood, the limiting LOCBART or STRIKIN-II calculation will be rerun using the specified Optimized ZIRLOTM material properties. Although not a condition of approval, the NRC staff strongly recommends that, for future Page 11 of 17

ATTACHMENT 1 Evaluation of Proposed Changes evaluations, Westinghouse update all computer models with Optimized ZIRLOTM specific material properties.

RESPONSE: Braidwood and Byron are not licensed with LOCBART or STRIKIN-11.

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: For implementation of Optimized ZIRLOTM fuel cladding, the Peak Cladding Temperature (PCT) calculated for the locked rotor event will be assessed relative to the Westinghouse Optimized ZIRLOTM cladding 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 The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met.

10 CFR 50.46 provides acceptance criteria for emergency core cooling systems 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, the NRC issued a safety evaluation approving Addendum 1 to Westinghouse Topical Report WCAP-12610-P-A &

CENPD-404-P-A,T Optimized ZIRLOTM," wherein the NRC approved the use of Optimized ZIRLO as an acceptable fuel cladding material for Westinghouse and Combustion Engineering (CE) fuel designs (Reference 2).

EGC evaluated the proposed change to determine whether applicable regulations and requirements continue to be met. This determination found that the proposed change to allow the use of Optimized ZIRLOTM 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 Appendix K to 10 CFR 50, "ECCS Evaluation Models." provides the basis and justification for exemption from these regulations.

Page 12 of 17

ATTACHMENT 1 Evaluation of Proposed Changes 4.2

Precedent As part of the industry focus to minimize the potential for fuel failure, the following licensees have received staff approval to use Optimized ZIRLOTM fuel cladding:

Letter from J. G. Lamb (U. S. Nuclear Regulatory Commission) to K. Walsh (NextEra Energy Seabrook, LLC), "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) (Reference 11).

Letter from J. Kim (U. S. Nuclear Regulatory Commission) to D. A. Heacock (Dominion), "Millstone Power Station Unit No. 3 - Issuance of Amendment Re: the Use of Optimized ZIRLOTM Fuel Rod Cladding (TAC No. ME7663),"

September 24, 2012 (ADAMS Accession No. ML12236A396) (Reference 12).

Letter from J. S. Wiebe (U. S. Nuclear Regulatory Commission) to D. A. Heacock (Dominion), "North Anna Power Station, Unit Nos. 1 and 2, Issuance of Amendments Regarding the Use of Optimized ZIRLOTM Fuel Rod Cladding (TAC Nos. ME3885 and ME3886)," April 14, 2011 (ADAMS Accession No. ML110601196) (Reference 13).

4.3

No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests an amendment to Renewed Facility Operating License Nos. NPF-72 and NPF-77 for Braidwood Station, Units 1 and 2 (Braidwood), and Renewed Facility Operating License Nos. NPF-37 and NPF-66 for Byron Station, Units 1 and 2 (Byron).

This amendment request proposes to allow the use of Optimized ZIRLOTM fuel cladding material consistent with the U. S. Nuclear Regulatory Commission (NRC) allowed use of Optimized ZI RLOTM 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 M." In support of this change, EGC proposes to revise the Braidwood and Byron Technical Specifications (TS) 4.2.1, "Reactor Core, Fuel Assemblies," to add Optimized ZI RLO' M as an approved fuel rod cladding, and EGC proposes to revise Braidwood and Byron TS 5.6.5.b, "Core Operating Limits Report (COLR)," to add Westinghouse topical report WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOTM," to the current list of NRC approved analytical methods used to determine the core operating limits. EGC proposes to add the Westinghouse topical report for ZIRLO° (i.e., WCAP-12610-P-A) to the current list in TS 5.6.5.b of NRC approved analytical methods used to determine the core operating limits as this WCAP was previously approved by the NRC for Braidwood and Byron by NRC letter dated December 19, 1995. In addition, a non-technical change is proposed in the form of a revision to the title of Reference 11 in TS 5.6.5.b to correct a grammatical error (i.e., replacing a semicolon with a period) introduced in Amendments 174 and 181 to Braidwood and Byron, respectively, dated February 7, 2014.

Page 13 of 17

ATTACHMENT 1 Evaluation of Proposed Changes According to 10 CFR 50.92, "Issuance of amendment," paragraph (c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

(1)

Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2)

Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3)

Involve a significant reduction in a margin of safety.

EGC has evaluated the proposed changes for Braidwood and Byron, using the criteria in 10 CFR 50.92, and has determined that the proposed changes do not involve a significant hazards consideration. The following information is provided to support a finding of no significant hazards consideration.

Criteria 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 reactors. The NRC approved topical report WCAP-12610-P-A &

CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOTM,,, prepared by Westinghouse Electric Company LLC (Westinghouse), addresses Optimized ZIRLOTM and demonstrates that Optimized ZIRLOTM has essentially the same properties as currently licensed ZIRLOO'. The fuel cladding itself is not an accident initiator and does not affect accident probability. With the approved exemption, use of Optimized ZIRLOTM fuel cladding will continue to meet all 10 CFR 50.46 acceptance criteria and, therefore, will not increase the consequences of an accident. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

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

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 ZI RLOO, thus precluding the possibility of the fuel cladding becoming an accident initiator and causing a new or different type of accident.

Page 14 of 17

ATTACHMENT 1 Evaluation of Proposed Changes Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3.

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

Response: No.

The proposed change will not involve a significant reduction in the margin of safety. Topical Report WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, demonstrated that the material properties of the Optimized ZIRLOTM are not significantly different from those of standard ZI RLO°. Optimized ZIRLOTM is expected to perform similarly to standard ZIRLOO 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 is Optimized ZIRLOTM material properties relative to standard ZIRLO" could have some impact on the overall accident scenario, plant-specific LOCA analyses using Optimized ZIRLOTM 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, EGC concludes that the proposed amendment to allow the use of Optimized ZIRLOTM fuel cladding material does not involve a 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 CONSIDERATION==

EUG has evaluated the proposed amendment for environmental considerations. The review has resulted in the determination that the proposed amendment 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, and would change an inspection or surveillance requirement. However, the proposed 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 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.

Page 15 of 17

ATTACHMENT 1 Evaluation of Proposed Changes

6.0 REFERENCES

1)

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

2)

Letter from H. N. Berkow (USNRC) to J. A. Gresham (Westinghouse), "Final Safety Evaluation for Addendum 1 to Topical Report WCAP-12610-P-A & CENPD-404-P-A,

'Optimized ZI RLOT14 "" June 10, 2005.

3)

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 ZIRLOTM (Proprietary/Non-proprietary)," LTR-NRC-07-1, January 4, 2007.

4)

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 ZIRLOTM (Proprietary/Non-proprietary)," LTR-NRC-07-58, November 6, 2007.

5)

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 ZIRLOTM (Proprietary/Non-proprietary)," LTR-NRC-07-58, Rev. 1, February 5, 2008.

6)

Letter from J. A. Gresham (Westinghouse) to U. S. Nuclear Regulatory Commission, "SER Compliance of WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A 'Optimized ZI RLOTM (Proprietary/Non-proprietary)," LTR-NRC-08-60, December 30, 2008.

7)

Letter from J. A. Gresham (Westinghouse) to U. S. Nuclear Regulatory Commission, "SER Compliance of WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A 'Optimized ZI RLOTM (Proprietary/Non-Proprietary)," LTR-NRC-10-43, July 26, 2010.

8)

Letter from James A. Gresham (Westinghouse) to U. S. Nuclear Regulatory Commission, "SER Compliance of WCAP-12610-P-A & CEN PD-404-P-A Addendum 1-A 'Optimized ZIRLOTMI (Proprietary/Non-Proprietary)," LTR-NRC-13-6, February 25, 2013.

9)

Letter from James A. Gresham (Westinghouse) to U. S. Nuclear Regulatory Commission, "Submittal of Responses to Draft RAls and Revisions to Select Figures in LTR-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.

10)

Letter from James. A. Gresham (Westinghouse) to U. S. Nuclear Regulatory Commission, "Submittal of Response to Condition 8.a of the Safety Evaluation Report (SER) on WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A, 'Optimized ZIRLOTM,' (Proprietary/Non-Proprietary)," LTR-NRC-15-84, September 29, 2015.

11)

Letter from J. G. Lamb (U. S. Nuclear Regulatory Commission) to K. Walsh (NextEra Energy Seabrook, LLC), "Seabrook Station, Unit No. 1 - Issuance of Amendment Regarding the Use of Optimized ZIRLOTM Fuel Rod Cladding Material JAC No. MF2410)," March 5, 2014 (ADAMS Accession No. ML13213A143).

Page 16 of 17

ATTACHMENT 1 Evaluation of Proposed Changes

12)

Letter from J. Kim (U. S. Nuclear Regulatory Commission) to D. A. Heacock (Dominion),

"Millstone Power Station Unit No. 3 - Issuance of Amendment Re: the Use of Optimized ZIRLOTM Fuel Rod Cladding (TAC No. ME7663)," September 24, 2012 (ADAMS Accession No. ML12236A396).

13)

Letter from J. S. Wiebe (U. S. Nuclear Regulatory Commission) to D. A. Heacock (Dominion), "North Anna Power Station, Unit Nos. 1 and 2, Issuance of Amendments Regarding the Use of Optimized ZI RLOTm Fuel Rod Cladding (TAC Nos. ME3885 and ME3886)," April 14, 2011 (ADAMS Accession No. ML110601196).

14)

WCAP-12610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report," April 1995.

15)

Letter from G. F. Dick (U. S. Nuclear Regulatory Commission) to D. L. Farrar (Commonwealth Edison Company), "Issuance of Amendments," (TAC Nos. M93631, M93632, M93633 and M93634)," December 19, 1995 (ADAMS Accession No.

MI-020870278).

16)

Letter from J. S. Wiebe (U. S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Generation Company, LLC), "Braidwood Station, Units 1 and 2, and Byron Station, Unit Nos. 1 and 2 Issuance of Amendments Regarding Measurement Uncertainty Recapture Power Uprate (TAC Nos. MF2418, MF2419, MF2420, and MF2421)," February 7, 2014 (ADAMS Accession No. ML13281A000).

Page 17 of 17

ATTACHMENT Exemption Request BRAIDWOOD STATION UNITS 1 AND 2 BYRON STATION UNITS 1 AND 2 5 pages follow

ATTACHMENT 2 Exemption Request 1.0

SUMMARY

DESCRIPTION Exelon Generation Company, LLC (Exelon) requests an exemption from the provisions of 10 CFR 50.46, "Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors," and Appendix K to 10 CFR Part 50, "ECCS Evaluation Models," to allow the use of Optimized ZIRLO M High Performance Fuel Cladding Material in future core reload applications for Braidwood Station, Units 1 and 2 (Braidwood) and Byron Station, Units 1 and 2 (Byron). 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 Cladding Material. Appendix K to 10 CFR Part 50, paragraph I.A.5, requires the Baker-Just equation to be used to predict the rates of energy release, hydrogen generation, and cladding oxidation from the metal-water reaction. The Baker-Just equation assumed the use of a zirconium alloy different than Optimized ZIRLOTM material. Therefore, an exemption to 10 CFR 50.46 and 10 CFR Part 50, Appendix K is required to support the use of Optimized ZIRLOTM fuel rod cladding. The exemption request relates solely to the 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 K to 10 CFR Part 50 to fuel assembly designs utilizing Optimized ZI RLOTM 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.

EGC currently plans to use Optimized ZIRLOTM as the fuel rod cladding material for Braidwood and Byron reloads starting with the new fuel introduced for Braidwood, Unit 1, Cycle 21, which is scheduled to begin in the spring of 2018.

Technical Specification (TS) changes for Braidwood and Byron are required to allow the use of Optimized ZIRLOTM fuel rod cladding for core reload applications. The request for the TS changes is provided in Attachment 1 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 testing of Optimized ZIRLOTM material compared to standard ZIRLO° material as well as the material properties to be used in various models and methodologies when analyzing Page 1 of 5

ATTACHMENT 2 Exemption Request Optimized ZIRLOTM fuel rod cladding. The Nuclear Regulatory Commission (NRC) Safety Evaluation for WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, (Reference 2) contains ten conditions and limitations. The first condition requires an exemption from 10 CFR 50.46 and 10 CFR Part 50, Appendix K, which is being requested via this letter. 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. Conditions and limitations 8.b and 9 do not apply because Braidwood and Byron do not have a Combustion Engineering (CE) fuel design and are not licensed with LOCBART or STRIKIN-II. The remaining conditions and limitations will be addressed in the Braidwood and Byron TS changes and evaluations required to support core reload activities. Since plant-specific TS changes are required prior to utilizing Optimized ZIRLO TM fuel rod cladding, no new commitments are necessary to support NRC approval of this exemption request.

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

4.0

JUSTIFICATION OF EXEMPTION 10 CFR 50.12, "Specific exemptions," states that the NRC may grant exemptions from the requirements of the regulations of this part provided two conditions are met. They are: (1) the exemption is authorized by law; the exemption will not present an undue risk to the health and safety of the public; and the exemption is 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 ZIRLOTM fuel rod cladding material in addition to Zircaloy or ZIRLO° material for core reload applications at Braidwood and Byron satisfies these criteria as described below.

C;nnc-fitinn 1

1. 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 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, Braidwood and Byron do not seek an exemption from the acceptance and analytical criteria of 10 CFR 50.46 and 10 CFR Part 50, Appendix K. The intent of the request is solely to allow the use of criteria set forth in these regulations for application to the Optimized ZIRLOTM fuel rod cladding material.

Page 2 of 5

ATTACHMENT 2 Exemption Request

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 Braidwood and Byron are supported by the applicable site specific TS. Reload cores are required to be operated in accordance with the operating limits specified in the TS. Thus, the granting of this exemption request will not pose an undue risk to public health and safety.

3. This exemption is consistent with common defense and security.

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

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

10 CFR 50.46 identifies acceptance criteria for ECCS performance at nuclear power plants.

Due to the similarities in the properties of Optimized ZIRLOTM material and standard ZIRLOO material, the current ECCS analysis approach remains applicable. Westinghouse will perform an evaluation of the Braidwood and Byron core using Loss of Coolant Accident T(LOCA) methods approved for the site to ensure that assemblies with Optimized ZIRLOTM fuel rod cladding material meet all LOCA safety criteria.

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

Page 3 of 5

ATTACHMENT 2 Exemption Request

5.0 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 ZIRLOTM fuel rod cladding material since Optimized ZIRLOTM material has a slightly different composition than Zircaloy or ZIRLO material. With the approval of this exemption request, these regulations will be applied to Optimized 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.

6.0 REFERENCES

1)

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

2)

Letter from H. N. Berkow (USNRC) to J. A. Gresham (Westinghouse), "Final Safety Evaluation for Addendum 1 to Topical Report WCAP-12610-P-A & CENPD-404-P-A,

'Optimized ZIRLOTM'," June 10, 2005.

3)

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 ZIRLOTM' (Proprietary/Non-proprietary)," LTR-NRC-07-1, January 4, 2007.

4)

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 ZIRLOTM' (Proprietary/Non-proprietary)," LTR-NRC-07-58, November 6, 2007.

5)

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 ZIRLOTM' (Proprietary/Non-proprietary)," LTR-NRC-07-58, Rev. 1, February 5, 2008.

6)

Letter from J. A. Gresham (Westinghouse) to U. S. Nuclear Regulatory Commission, "SER Compliance of WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A 'Optimized ZIRLOTM' (Proprietary/Non-proprietary)," LTR-NRC-08-60, December 30, 2008.

7)

Letter from J. A. Gresham (Westinghouse) to U. S. Nuclear Regulatory Commission, "SER Compliance of WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A 'Optimized ZIRLOTM' (Proprietary/Non-Proprietary)," LTR-NRC-10-43, July 26, 2010.

8)

Letter from James A. Gresham (Westinghouse) to U. S. Nuclear Regulatory Commission, "SER Compliance of WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A

'Optimized ZIRLOTMI (Proprietary/Non-Proprietary)," LTR-NRC-13-6, February 25, 2013.

Page 4 of 5

ATTACHMENT 2 Exemption Request

9)

Letter from James A. Gresham (Westinghouse) to U. S. Nuclear Regulatory Commission, "Submittal of Responses to Draft RAls and Revisions to Select Figures in LTR-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.

10)

Letter from James. A. Gresham (Westinghouse) to U. S. Nuclear Regulatory Commission, "Submittal of Response to Condition 8.a of the Safety Evaluation Report (SER) on WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A, 'Optimized ZI RLOTM,'

(Proprietary/Non-Proprietary)," LTR-NRC-15-84, September 29, 2015.

Page 5 of 5

ATTACHMENT 3 Markup of Technical Specifications Pages BRAIDWOOD STATION UNITS 1 AND 2 Docket Nos. STN 50-456 and 50-457 Renewed Facility Operating License Nos. NPF-72 and NPF-77 REVISED TS PAGES 4.0-1 5.6-3 5.6-4 INSERT A

Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site 4.1.1 Site Location The site is located in Reed Township, approximately 20 mi (32 km) south-southwest of the city of Joliet in northern Illinois.

4.1.2 Exclusion Area Boundary (EAB)

The EAB shall not be less than 1591 ft (485 meters) from the outer containment wall.

4.1.3 Low Population Zone (LPZ)

The LPZ shall be a 1.125 mi (1811 meter) radius measured from the midpoint between the two reactors.

4.2 Reactor Core 4.2.1 Fuel Assemblies

, ZIRLO, or Optimized ZIRLOTM The reactor shal contain 193 fuel assemblies. Each assembly, with exceptions s noted below, shall consist of a matrix of Zircaloy

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 or vacancies 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.

Up to 8 AREUA NP Advanced Mark-BW(A) fuel assemblies containing M5 alloy may be placed in nonlimiting Unit 1 core regions for evdluaLiuri during Cycles 15, lb, and 11.

4.2.2 Control Rod Assemblies The reactor core shall contain 53 control rod assemblies. The control material shall be silver indium cadmium, hafnium, or a mixture of both types.

BRAIDWOOD UNITS 1 & 2

4.0 1 Amendment 445

Reporting Requirements NO CHANGE TO THIS PAGE -- PROVIDED FOR INFORMATION ONLY 1 5.6 5.6 Reporting Requirements 5.6.5

CORE OPERATING LIMITS REPORT (COLR)

a.

Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

SL 2.1.1, "Reactor Core SLs";

LCO 3.1.15 "SHUTDOWN MARGIN (SDM)";

LCO 3.1.3 9 "Moderator Temperature Coefficient";

LCO 3.1.5, "Shutdown Bank Insertion Limits";

LCO 3.1.6, "Control

Bank Insertion Limits";

LCO 3.1.8 9 "PHYSICS TESTS Exceptions - MODE 2";

LCO 3.2.19 "Heat Flux Hot Channel

Factor (F,(Z))

LCO 3.2.2, "Nuclear Enthalpy Rise Hot Channel

Factor (F1

LCO 3.2.3 9 "AXIAL FLUX DIFFERENCE (AFD)";

LCO 3.2.51 "Departure from Nucleate Boiling Ratio (DNBR)";

LCO 3.4.11 "RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB)

Limits";

and LCO 3.9.1, "Boron Concentration";

b.

The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

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

2.

WCAP-12472-P-A, "BEACON Core Monitoring and Operations Support System," August 1994.

3.

NFSR-0016, "Commonwealth Edison Company Topical Report on Benchmark of PWR Nuclear Design Methods," July 1983.

4.

NFSR-0081, "Commonwealth Edison Company Topical Report on Benchmark of PWR Nuclear Design Methods Using the Phoenix-P and ANC Computer Codes," July 1990.

BRAIDWOOD UNITS 1 & 2 5.6 3

Amendment 110

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5

CORE OPERATING LIMITS REPORT (COLR) (continued)

5.

ComEd letter from D. Saccomando to the Office of Nuclear Reactor Regulation dated December 21, 1994, transmitting an attachment that documents applicable sections of WCAP-11992/11993 and ComEd application of the UET methodology addressed in "Additional Information Regarding Application for Amendment to Facility Operating Licenses-Reactivity Control Systems."

6.

WCAP-16009-P-A, Revision 0, "Realistic Large-Break LOCA Evaluation Methodology Using the Automated Statistical Treatment of Uncertainty Method (ASTRUM)," January 2005.

7.

WCAP-10079-P-A, "NOTRUMP, A Nodal Transient Small Break and General Network Code," August 1985.

8.

WCAP-10054-P-A, "Westinghouse Small Break ECCS Evaluation Model using NOTRUMP Code," August 1985.

9.

WCAP-10216-P-A, Revision 1, "Relaxation of Constant Axial Offset Control - FQ Surveillance Technical Specification," February 1994.

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

September 1986.

I, GAD 14565 D A ~~VTnDE 01 Mndnl inn and (1iial i f i_eation

'YYG7T~ T ~~~ T T,~9Tf f"'~

Replace with INSERT A

I 1,Y U I U U 1 41 e Sa f ety AH a 1 ys i 5, 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; and

d.

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

BRAIDWOOD UNITS 1 & 2

5.6 4 Amendment 1~4

IN.qFRT A

11.

WCAP-14565-P-A, "VIPRE-01 Modeling and Qualification for Pressurized Water Reactor Non-LOCA Thermal-Hydraulic Safety Analysis," October 1999.

12.

WCAP-12610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report," April 1995. (Westinghouse Proprietary).

13.

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

ATTACHMENT 4 Markup of Technical Specifications Pages BYRON STATION UNITS 1 AND 2 Docket Nos. STN 50-454 and 50-455 Renewed Facility Operating License Nos. NPF-37 and NPF-68 REVISED TS PAGES 4.0-1 5.6-3 5.6-4 INSERT A

Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site 4.1.1 Site Location The site is located in Rockvale Township, approximately 3.73 mi (6 km) south-southwest of the city of Byron in northern Illinois.

4.1.2 Exclusion Area Boundary (EAB)

The EAB shall not be less than 1460 ft (445 meters) from the outer containment wall.

4.1.3 Low Population Zone (LPZ)

The LPZ shall be a 3.0 mi (4828 meter) radius measured from the midpoint between the two reactors.

4.2 Reactor Core 4.2.1 Fuel Assemblies

, ZIRLO, or Optimized ZIRLOTM The reactor shall contain 193 fuel assemblies

Each assembly shall consist of a matrix of Zircaloy

clad fuel rods with an initial composition of natural or slightly enriched uranium dioxide (UO) as fuel material. Limited substitutions of zirconium alloy or stainless steel filler rods or vacancies 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 material shall be -silver indium cadmium, hafnium, or a mixture of both types.

BYRON UNITS 1 & 2

4.0 1

Amendment 446

Reporting Requirements INO CHANGE TO THIS PAGE -- PROVIDED FOR INFORMATION ONLY 1 5.6 5.6 Reporting Requirements 5.6.5

CORE OPERATING LIMITS REPORT (COLR)

a.

Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

SL 2.1.1, "Reactor Core SLs";

LCO 3.1.19 "SHUTDOWN MARGIN (SDM)";

LCO 3.1.31 "Moderator Temperature Coefficient";

LCO 3.1.5, "Shutdown Bank Insertion Limits";

LCO 3.1.61 "Control Bank Insertion Limits";

LCO 3.1.8, "PHYSICS TESTS Exceptions - MODE 2";

LCO 3.2.11 "Heat Flux Hot Channel Factor (FQ(Z))

LCO 3.2.2, "Nuclear Enthalpy Rise Hot Channel Factor (F1) ";

LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)";

LCO 3.2.5 9 "Departure from Nucleate Boiling Ratio (DNBR)";

LCO 3.4.19 "RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits"; and LCO 3.9.1, "Boron Concentration";

b.

The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

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

2.

WCAP-12472-P-A, "BEACON Core Monitoring and Operations Support System," August 1994.

3.

NFSR-0016, "Commonwealth Edison Company Topical Report on Benchmark of PWR Nuclear Design Methods," July 1983.

4.

NFSR-0081, "Commonwealth Edison Company Topical Report on Benchmark of PWR Nuclear Design Methods Using the Phoenix-P and ANC Computer Codes," July 1990.

BYRON UNITS 1 & 2

5.6 3

Amendment 116

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5

CORL OPLRATING LIMITS REPORT (COLR) (continued)

5.

ComEd letter from D. Saccomando to the Office of Nuclear Reactor Regulation dated December 21, 1994, transmitting an attachment that documents applicable sections of WCAP-11992/11993 and ComEd application of the UET methodology addressed in "Additional Information Regarding Application for Amendment to Facility Operating Licenses-Reactivity Control Systems."

6.

WCAP-16009-P-A, Revision 0, "Realistic Large-Break LOCA Evaluation Methodology Using the Automated Statistical Treatment of Uncertainty Method (ASTRUM)," January 2005.

7.

WCAP-10079-P-A, "NOTRUMP, A Nodal Transient Small Break and General Network Code," August 1985.

8.

WCAP-10054-P-A, "Westinghouse Small Break ECCS Evaluation Model using NOTRUMP Code," August 1985.

9.

WCAP-10216-P-A, Revision 1, "Relaxation of Constant Axial Offset Control - F, Surveillance Technical Specification," February 1994.

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

September 1986.

Dn D

-Fnv~

v~nrri iv+i znrl 1.1-~i-nv+

-~ntnv. Alnvi ~ n('n Tl~nv+m-il Replace with INSERT A

HydpaHlie Safety Anaily5i5,"

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; and

d.

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

BYRON UNITS 1 & 2

5.6 4 Amendment 4-8

IN.qFRT A

11.

WCAP-14565-P-A, "VIPRE-01 Modeling and Qualification for Pressurized Water Reactor Non-LOCA Thermal-Hydraulic Safety Analysis," October 1999.

12.

WCAP-12610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report," April 1995. (Westinghouse Proprietary).

13.

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