NMP1L3122, License Amendment Request - Proposed Changes Regarding Partial Length Fuel Rod (PLR) Burnup

License Amendment Request - Proposed Changes Regarding Partial Length Fuel Rod (PLR) Burnup

ML17003A065
Person / Time
Site:	Nine Mile Point
Issue date:	01/03/2017
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NMP1L3122
Download: ML17003A065 (12)

Text

Exelon Generation ~

NMP1L3122 January 3, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Nine Mile Point Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-63 NRC Docket No. 50-220 200 Exelon Way l<ennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90

Subject:

License Amendment Request - Proposed Changes Regarding Partial Length FuelRod(PLR)Bumup In accordance with 1 O CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) requests an amendment to Renewed Facility Operating License No. DPR-63 for Nine Mile Point Nuclear Station, Unit 1 (NMP1). The proposed change would allow the use of the release fractions listed in Tables 1 and 3 of NRC Regulatory Guide (AG) 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," for Partial Length Fuel Rods (PLRs) that are operating above the peak bumup limit through the end of operating Cycle 22.

Footnotes 1 O and 11 of RG 1.183 identify the current rod peak bumup limit as 62,000 MWD/MTU. In addition, the proposed change would revise the NMP1 licensing basis to allow movement of irradiated fuel bundles containing PLRs that have been in operation above the 62,000 MWD/MTU. The Attachment provides a description and evaluation of the proposed change.

Currently, several peripheral GE11 fuel bundles were identified as containing partial length fuel rods which are or will be operating in excess of the peak burnup limitation of 62,000 MWD/MTU prior to the end of the current operating cycle for NMP1. A technical evaluation and an operability determination were performed to ensure continued safe operation of the reactor is maintained for the remainder of the operating cycle. Exelon requests approval of the proposed change by March 1, 2017, to support movement of the fuel bundles containing the affected PLRs from the reactor vessel to the spent fuel pool. Once approved, the amendment will be implemented prior to moving any of the affected fuel assemblies into the spent fuel pool.

The proposed change has been reviewed by the NMP Plant Operations Review Committee in accordance with the requirements of the Exelon Quality Assurance Program.

License Amendment Request Partial Length Rod Burnup Docket No. 50-220 January 3, 2017 Page 2 In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), Exelon is notifying the State of New York 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 in this letter.

If you have any questions or require additional information, please contact Ron Reynolds at (610) 765-5247.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 3rct day of January 2017.

Respectfully, llf ~ JJ. ad Jr-- =f--z-James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Evaluation of Proposed Changes cc:

Regional Administrator - NRG Region I NRG Senior Resident Inspector - NMP NRG Project Manager, NRR - NMP A. L. Peterson, NYSERDA w/ attachments

ATTACHMENT License Amendment Request

Subject:

Nine Mile Point Nuclear Station, Unit 1 Docket No. 50-220 EVALUATION OF PROPOSED CHANGES Proposed Changes to Partial Length Fuel Rod (PLR) Burnup 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

License Amendment Request NMP1 Partial Length Fuel Rod Burnup Docket No. 50-220 Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION Attachment Page 1 of 9 In accordance with 1 O CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) requests an amendment to Renewed Facility Operating License No. DPR-63 for Nine Mile Point Nuclear Station, Unit 1 (NMP1 ). The proposed change would allow the use of the release fractions listed in Tables 1 and 3 of NRG Regulatory Guide (RG) 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," (Reference 1) for Partial Length Fuel Rods (PLRs) that are operating above the peak burnup limit through the end of operating Cycle 22. Footnotes 1 O and 11 of RG 1.183 identify the current rod peak burnup limit as 62,000 MWD/MTU. In addition, the proposed change would revise the NMP1 licensing basis to allow movement of the irradiated fuel bundles which contain the PLRs in operation above the 62,000 Megawatt-Days per Metric Tons of Uranium (MWD/MTU) limit.

Currently, several peripheral GE11 fuel bundles were identified as containing PLRs which are or will be operating above the peak burnup limitation of 62,000 MWD/MTU prior to the end of the current operating cycle for NMP1. A technical evaluation and an operability determination were performed to ensure continued safe operation of the reactor is maintained for the remainder of the operating cycle. Therefore, Exelon requests approval of the proposed change by March 1, 2017, to support movement of the fuel bundles containing the affected PLRs from the reactor vessel to the spent fuel pool. Once approved, the amendment will be implemented prior to moving any of the affected fuel assemblies into the spent fuel pool. Accordingly, this issue is being addressed in the site's Corrective Action Program (CAP).

2.0 DETAILED DESCRIPTION The NRG issued amendment 194 to the facility operating license for NMP1 (Reference 2). The amendment supports the application of Alternative Source Term (AST) methodology with respect to the Loss-Of-Coolant Accident (LOCA), the Fuel Handling Accident (FHA), and the Control Rod Drop Accident (CADA). Exelon's AST analyses for NMP1 were performed following the guidance in NRG RG 1.183; Standard Review Plan 15.0.1, "Radiological Consequence Analyses Using Alternative Source Terms" (Reference 3); and 1 O CFR 50.67, "Accident source term."

Section 3 of Reference 1 provides an AST that is acceptable to the NRG, and indicates that once approved, the AST assumptions or parameters specified in the positions described in Section 3 become part of the facility's design basis. After the NRG has approved an implementation of an AST, subsequent changes to the AST require NRG review under 10 CFR 50.67.

The NMP1 AST analyses used the core inventory release fractions for the gap release and early in-vessel damage phases for the Design Basis Accident (OBA) LOCA that are listed in Table 1 of Reference 1. For the FHA and CADA events, the NMP1 analyses used the fractions of the core inventory assumed to be in the gap for the various radionuclides in Table 3 of Reference 1.

These release fractions were used in conjunction with the fission product inventory calculated with the maximum core radial peaking factor.

License Amendment Request NMP1 Partial Length Fuel Rod Burnup Docket No. 50-220 Evaluation of Proposed Changes Attachment Page 2 of 9 The discussion of release fractions in Reference 1 is annotated with the following footnote:

1°The release fractions listed here have been determined to be acceptable for use with currently approved LWR fuel with a peak burnup up to 62,000 MWD/MTU. The data in this section may not be applicable to cores containing mixed oxide (MOX) fuel.

In addition, Table 3 of Reference 1 is annotated with the following footnote:

11The release fractions listed here have been determined to be acceptable for use with currently approved LWR fuel with a peak burnup up to 62,000 MWD/MTU provided that the maximum linear heat generation rate does not exceed 6.3 kw/ft peak rod average power for burnups exceeding 54 GWD/MTU. As an alternative, fission gas release calculations performed using NRG-approved methodologies may be considered on a case-by-case basis. To be acceptable, these calculations must use a projected power history that will bound the limiting projected plant-specific power history for the specific fuel load. For the BWR rod drop accident and the PWR rod ejection accident, the gap fractions are assumed to be 10% for iodines and noble gases.

On February 18, 2015, it was determined that NMP1 Cycle 22 core design will not meet the Regulatory Guide 1.183 limit for peak rod exposure of 62,000 MWD/MTU for certain PLRs in GE11 fuel bundles and placed into Exelon's Corporate CAP (Issue Report 02454608).

Subsequently, it was determined that an analytical solution to resolve the issue was not going to be successful; therefore, on June 8, 2016, Issue Report 02679056 was initiated within the site's CAP. On November 9, 2016, Issue Report 02739019 was initiated to capture the impact on the LOCA dose analysis within the site's CAP. Technical evaluations were performed to evaluate the safety significance of the non-conforming PLRs. These technical evaluations were used as supporting references for operability determination in accordance with Exelon's Operability Determination Process.

The FHA and CRDA technical evaluation concluded that the end of life burnup of the worst PLRs is less than the average burnup of the same nodes in the worst FLRs. In addition the power profiles of the worst PLRs are consistent with NUREG/CR-6703. Therefore, the gap fractions of the worst PLRs remain consistent with those determined in NUREG/CR-6703 and prescribed in RG 1.183.

The LOCA technical evaluation concluded that the small number of PLRs that are projected to exceed or come close to exceeding the 62,000 MWD/MTU limit by the end of the current operating cycle would not result in doses from a LOCA exceeding the current licensing basis results.

The proposed change would allow the use of the release fractions listed in Tables 1 and 3 of Reference 1 for the PLRs that are currently in the Cycle 22 reactor core for the remainder of the current operating cycle. In addition, the proposed change would revise the NMP1 licensing basis to allow movement of irradiated fuel bundles containing PLRs that have been in operation above 62,000 MWD/MTU.

License Amendment Request NMP1 Partial Length Fuel Rod Burnup Docket No. 50-220 Evaluation of Proposed Changes

3.0 TECHNICAL EVALUATION

Attachment Page 3 of 9 The fuel bundles containing PLRs that have exceeded, or are projected to exceed, the 62,000 MWD/MTU burnup limit are GE11 fuel bundles. There are 40 PLRs that are projected to exceed this limit by the end the current operating cycle for NMP1 (i.e., Cycle 22} by a maximum of 2, 100 MWD/MTU. In addition, another 3 PLRs are projected to come within 100 MWD/ST of exceeding the limit. A total of 20 bundles are projected to contain PLRs exceeding the limit.

The GE11 PLR is a fuel rod that is shorter than a Full Length Fuel Rod (FLA), and is located in the bottom portion of the reactor core. It has less Uranium content and, as a result of the axial power distribution due to voiding in the top of the core, experiences higher rod-average exposure. However, it is very similar to the corresponding segment of the FLA. Essentially the segment is the same as a FLA, except it has the top portion of Uranium removed. Using this equivalence aspect and a gap fraction calculation procedure, a comparative analysis was performed to determine the impact on the FHA and CADA analyses and to demonstrate that a PLR is bounded by a FLR.

The scope of the FHA and CADA evaluation is limited to the GE11 fuel design at NMP1.

Reference 1 provides gap release fractions for non-LOCA events in Table 3. These gap release fractions were developed prior to July 2000 and do not explicitly address PLRs. For NMP1, the FHA and CADA are the two applicable non-LOCA events that use AST methodology in the radiological consequence analyses.

A calculation procedure available to assess the gap inventory is specified in ANSl/ANS-5.4-2011, "Method for Calculating the Fractional Release of Volatile Fission Products from Oxide Fuel," (i.e., Reference 4) to assess the gap inventory. In that calculation procedure, the fractional release of fission gases is computed in a radial and axial (nodal) domain that represents the Uranium Oxide fuel pellet stack. The release fraction is computed as a function of burnup and the power, both of which determine how much gas diffusion out of the pellet stack occurs. The effective release fraction is then computed by a volume and power weighted average of the spatial dependent release fractions. The evaluation used this approach to demonstrate that the gap release fraction of the PLR is bounded by the FLA, given operational characteristics inherent to the PLRs.

The evaluation demonstrates that the power and burnup for a GE11 PLR is bounded by the power and burnup in the same axial portion of several neighboring FLRs. Figure 1 summarizes the results of this evaluation by showing the comparison of the PLRs with the highest projected burnup. The Figure 1 shows that the PLR burnup profile is less than the average burnup of the same nodes in the worst FLRs. Therefore, since the FLA operating characteristics bound the PLR, and since the power and burnup of the FLRs comply with the limits specified in Footnotes 1 o and 11 of Reference 1, the GE11 PLRs may operate beyond the 62,000 MWD/MTU burnup limit and meet the intent of Reference 1 (i.e., there is no increase in the gap release fraction required).

License Amendment Request NMP1 Partial Length Fuel Rod Burnup Docket No. 50-220 Evaluation of Proposed Changes Figure 1-NMP1 Average Over PLR Fueled Nodes, Projected EOC 22 Attachment Page 4 of 9 60.0 ~-----------------------

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40.0 +------------,..w-------------

0 3:

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PLR MAX E 3o.o +---------:di~---------------

I CD CIJ 1111

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~ 20.0 10.0 -!----,/#---------------------

0.0 l!1'-----,----,-----,-----,----.------,-----,

0 500 1000 1500 2000 2500 3000 3500 Burnup Step A NMP1 GE11 fuel bundle contains 66 full length rods and 8 PLRs. There are 71 equivalent FLRs per bundle. In the FHA it is assumed that the activity associated with two fuel bundles is released. A design basis FHA involving GE11 fuel damages 140 fuel rods. If the activity of the FLRs are substituted for the PLRs the GE11 FHA release would be equivalent to the activity associated with 1.97 fuel bundles. Therefore, since the GE11 FLRs meets the intent of the Reference 1 Footnote 11, the current FHA dose analysis remains bounding.

Similar to the FHA, the NMP1 CADA assumes a conservative core damage fraction of 2.58%

corresponding to 8x8 fuel. A design basis CADA involving GE11 fuel damages less than 2.54%

of equivalent FLRs. Therefore, since the GE11 FLRs meet the intent of the Reference 1 Footnote 11, the current CADA dose analysis remains bounding.

Exelon has also performed an evaluation to assess the impact of considering the NMP1 Cycle 22 specific core design on the AST LOCA dose analysis, and to further show that the consequences of a small number of PLRs in the GE11 batch exceeding the 62,000 MWD/MTU peak rod average limit in Footnote 1 O of Reference 1 will not cause LOCA doses to exceed the current analysis of record results. The impact of PLRs exceeding 62,000 MWD/MTU was determined using the same method of substituting FLR activity for PLR activity. Since the FLR

License Amendment Request NMP1 Partial Length Fuel Rod Burnup Docket No. 50-220 Evaluation of Proposed Changes Attachment Page 5 of 9 power and burnup is more limiting, it can be used to satisfy the Reference 1 Footnote 1 O burnup restrictions, and the LOCA release fractions can be applied unchanged provided FLRs are analytically substituted for PLRs which exceed 62,000 MWD/MTU. The current analysis of record determined the post-LOCA control room dose is 4.81 rem TEDE, which is the most limiting with respect to the 10 CFR 50.67 limits. Using a NMP1 Cycle 22 cycle-specific core inventory and substituting the activity of all PLRs in the GE11 batch (344 PLRs) with that of the FLRs results in a control room dose of 4.80 rem TEDE. Therefore, it is concluded that the small number of NMP1 Cycle 22 GE11 PLRs that are projected to exceed or come close to exceeding the 62,000 MWD/MTU limit by the end of the current operating cycle would not result in doses from a LOCA exceeding the current licensing basis results.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria In accordance with 1 O CFR 50.67, a licensee may revise its current AST by re-evaluating the consequences of DBAs with the AST. In Reference 2, the NRC approved the application of AST methodology at NMP1. The guidance associated with the implementation of an AST is provided in NRC Regulatory Guide 1.183 (Reference 1 ),

which states that subsequent changes to the AST require NRC review under 1 O CFR 50.67.

Fundamental to the definition of an AST according to Reference 1 are the release fractions. Table 1 of Reference 1 provides core inventory release fractions, by radionuclide groups, for the gap release and early in-vessel damage phases for OBA LOCAs. These fractions are applied to the equilibrium core inventory developed for NMP1. Footnote 1 O limits the peak burnup to 62,000 MWD/MTU. Table 3 of Reference 1 provides gap release fractions for various volatile fission product isotopes and isotope groups, to be applied to non-LOCA accidents. Footnote 11 of Table 3 limits the peak burnup to 62,000 MWD/MTU provided that the maximum linear heat generation rate does not exceed 6.3 kw/ft peak rod average power for burnups exceeding 54,000 MWD/MTU. As an alternative, fission gas release calculations performed using NRC-approved methodologies may be considered on a case-by-case basis. To be acceptable, these calculations must use a projected power history that will bound the limiting projected plant-specific power history for the specific fuel load. For the BWR rod drop accident and the PWR rod ejection accident, the gap fractions are assumed to be 10% for Iodines and noble gases.

Exelon's analyses demonstrate that the radiological consequences of a FHA, CRDA and LOCA are not affected by the proposed change.

4.2 Precedent Letter from B. Vaidya (NRC) to B. Hanson (Exelon), "LaSalle County Station, Units 1 and 2-Issuance of Amendments Re: High Burnup ATRIUM-10 Partial Length Fuel Rods (CAC Nos. MF8442 and MF8443), dated November 18, 2016 (ML16320A182).

License Amendment Request NMP1 Partial Length Fuel Rod Burnup Docket No. 50-220 Evaluation of Proposed Changes 4.3 No Significant Hazards Consideration Attachment Page 6 of 9 In accordance with 1 O CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) requests an amendment to Renewed Facility Operating License No. DPR-63 for Nine Mile Point Nuclear Station, Unit 1 (NMP1 ). The proposed change would allow the use of the release fractions listed in Table 1 of NRC Regulatory Guide 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," for PLRs that are currently in the Cycle 22 reactor core for the remainder of the current operating cycle. These PLRs exceed or are expected to exceed 62,000 MWD/MTU, which is the current rod peak burnup limit specified in Footnotes 1 O and 11 of NRC Regulatory Guide 1.183 prior to the end of the operating cycle. In addition, the proposed change would revise the NMP1 licensing basis to allow movement of irradiated fuel bundles containing PLRs that have been in operation above the 62,000 MWD/MTU limit.

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 any 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.

Exelon has evaluated the proposed change, using the criteria in 1 O CFR 50.92, and has determined that the proposed change does not involve a significant hazards consideration. The following information is provided to support a finding of no significant hazards consideration.

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 the release fractions listed in Tables 1 and 3 of NRC RG 1.183 for PLRs which are currently in the NMP1 Cycle 22 reactor core that are expected to exceed the 62,000 MWD/MTU rod peak burnup limit specified in Footnotes 1 O and 11 of NRC RG 1.183 prior to the end of the operating cycle. In addition, the proposed change would revise the NMP1 licensing basis to allow movement of irradiated fuel bundles containing PLRs that have been in operation above the 62,000 MWD/MTU limit. The proposed change does not involve any physical changes to the plant design and is not an initiator of an accident. The proposed change does not adversely affect accident initiators or precursors, and does not alter the design assumptions,

License Amendment Request NMP1 Partial Length Fuel Rod Burnup Docket No. 50-220 Evaluation of Proposed Changes Attachment Page 7 of 9 conditions, or configuration of the plant or the manner in which the plant is operated or maintained. Therefore, the proposed change does not affect the probability of a loss-of-coolant accident or control rod drop accident. In addition, the proposed change does not affect the probability of a fuel handling accident because the method and frequency of fuel movement activities are not changing.

Analyses have been performed that demonstrate that the power and burnup for a PLR is bounded by the power and burnup in the same axial portion of neighboring FLRs. Therefore, since the FLR operating characteristics bound the PLR, and since the power and burnup of the FLRs comply with the limits specified in Footnotes 10 and 11 of NRG RG 1.183, the PLRs may operate beyond the 62,000 MWD/MTU burnup limit and meet the intent of NRG RG 1.183. There are no changes in the dose consequences of the analyses of record for the fuel handling accident, control rod drop accident and loss-of-coolant 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 The proposed change would allow the use of the release fractions listed in Tables 1 and 3 of NRG RG 1.183 for PLRs which are currently in the NMP1 Cycle 22 reactor core that are expected to exceed the 62,000 MWD/MTU rod peak burnup limit specified in Footnotes 1 O and 11 of NRG RG 1.183 prior to the end of the operating cycle. In addition, the proposed change would revise the NMP1 licensing basis to allow movement of irradiated fuel bundles containing PLRs that have been in operation above the 62,000 MWD/MTU limit. The proposed change does not introduce any changes or mechanisms that create the possibility of a new or different kind of accident. The proposed change does not install any new or different type of equipment, and installed equipment is not being operated in a new or different manner. No new effects on existing equipment are created nor are any new malfunctions introduced.

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

3.

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

Response: No The proposed change would allow the use of the release fractions listed in Tables 1 and 3 of NRG RG 1.183 for PLRs which are currently in the NMP1 Cycle 22 reactor core that are expected to exceed the 62,000 MWD/MTU rod peak burnup limit specified in Footnotes 10 and 11 of NRG RG 1.183 prior to the

License Amendment Request NMP1 Partial Length Fuel Rod Burnup Docket No. 50-220 Evaluation of Proposed Changes Attachment Page 8 of 9 end of the operating cycle. In addition, the proposed change would revise the NMP1 licensing basis to allow movement of irradiated fuel bundles containing PLRs that have been in operation above the 62,000 MWD/MTU limit. Analyses have been performed that demonstrate that the power and burnup for a PLR is bounded by the power and burnup in the same axial portion of neighboring FLRs.

There is no change in the dose consequences of the fuel handling accident, control rod drop accident or loss-of-coolant accident analyses of record. The margin of safety, as defined by 1 O CFR 50.67 and NRC RG 1.183, has been maintained.

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

Based on the above evaluation, Exelon concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 1 O CFR 50.92, paragraph (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 the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

Exelon has determined 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 1 o CFR 20, "Standards for Protection Against Radiation." 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

License Amendment Request NMP1 Partial Length Fuel Rod Burnup Docket No. 50-220 Evaluation of Proposed Changes Attachment Page 9 of 9 1 O CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review,"

paragraph (c)(9). Therefore, pursuant to 10 CFR 51.22, paragraph (b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

6.0 REFERENCES

1 NRG Regulatory Guide 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," dated July 2000.

2.

Letter from M. David (U.S. NRG) to K. Polson (NMP), "Nine Mile Point Nuclear Station, Unit 1 - Issuance of Amendments Re: Implementation of Alternative Radiological Source Term" (TAC No. MD3896), dated December 19, 2007.

3.

NRG Standard Review Plan 15.0.1, "Radiological Consequence Analyses Using Alternative Source Terms," Revision 0, dated July 2000.

4.

ANSl/ANS-5.4-2011, "Method for Calculating the Fractional Release of Volatile Fission Products from Oxide Fuel"