ML25178A294

Constellation Energy Generation, Llc., - License Amendment Request - Application to Revise License Condition 2.b.(2) and Restore Technical Specification 5.4.1 to Allow Receipt of New Reactor Fuel

ML25178A294
Person / Time
Site:	Crane
Issue date:	06/27/2025
From:	Moore D AmerGen Energy Co, Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
CCEC-25-002
Download: ML25178A294 (1)

Text

200 Energy Way Kennett Square, PA 19348 www.constellation.com 10 CFR 50.90 CCEC-25-002 June 27, 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Christopher M. Crane Clean Energy Center Renewed Facility License No. DPR-50 NRC Docket No. 50-289

Subject:

License Amendment Request - Application to Revise License Condition 2.b.(2) and Restore Technical Specification 5.4.1 to Allow Receipt of New Reactor Fuel

References:

1) Constellation Energy Generation, LLC Press Release: Constellation to Launch Crane Clean Energy Center, Restoring Jobs and Carbon-Free Power to The Grid1

2) Letter from David M. Gullott (Constellation Energy Generation, LLC) to U.S.

Nuclear Regulatory Commission - Regulatory Path to Reauthorize Power Operations dated November 4, 2024 (ML24310A104)

On September 20, 2024, Constellation Energy Generation, LLC (CEG) announced its intention to restart Three Mile Island, Unit 1 (TMI-1) and to change TMI-1s name to the Christopher M. Crane Clean Energy Center (Crane Clean Energy Center or Crane) (Reference 1).

On November 4, 2024, CEG submitted the Regulatory Path to Reauthorize Power Operations (Reference 2). In that submittal, CEG described the approach to restoration of the Operating Reactor License Basis (ORLB). Restoration of the ORLB is necessary to support placing new fuel in the reactor and commence power operations.

CEG intends to receive, possess, and store new reactor fuel and new sealed neutron sources for reactor startup at Crane prior to restoring the ORLB and, therefore, a revision to the current licensing basis and Permanently Defueled Technical Specifications (PDTS) is necessary to support receiving new fuel.2 As such, and in accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," CEG requests an amendment to Renewed Facility License (RFL) No. DPR-50 to revise license condition 2.b.(2), applicable to byproduct, source and special 1 https://www.constellationenergy.com/newsroom/2024/Constellation-to-Launch-Crane-Clean-Energy-Center-Restoring-Jobs-and-Carbon-Free-Power-to-The-Grid.html

U.S. Nuclear Regulatory Commission Page 2 License Amendment Request - New Fuel Receipt Docket No. 50-289 June 27, 2025 nuclear material, to support receipt of new reactor fuel and new sealed neutron sources prior to restoration of the ORLB. Additionally, CEG requests to revise Technical Specification (TS) 5.0 Design Features to restore TS 5.4.1 applicable to New Fuel Storage. PDTS 5.2.1, which prevents storage of spent fuel in the spent fuel pools, is unaffected by the proposed amendment.

CEG has concluded that the proposed change involves a no significant hazard consideration" under the standards set forth in 10 CFR 50.92, Issuance of amendment.

The proposed changes have been reviewed and approved by the Crane Plant Operations Review Committee in accordance with the requirements of the Crane Restoration Quality Assurance Program.

provides a summary of proposed regulatory commitments. Attachment 2 provides an evaluation of the proposed change. Attachment 3 provides a copy of the marked-up RFL and TSs that reflect the proposed changes.

CEG requests approval of the proposed amendment by July 31, 2026. Upon NRC approval, CEG will implement the amendment within 30 days of issuance.

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

CEG is notifying the Commonwealth of Pennsylvania of this application by transmitting a copy of this letter and its attachments to the designated State Official.

Should you have any questions concerning this letter, please contact Christian Williams at 732-281-9104.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 27th day of June 2025.

Respectfully, Dennis M. Moore Senior Manager, Licensing Constellation Energy Generation, LLC Attachment(s):

1.

Summary of Regulatory Commitments

2.

Evaluation of Proposed Changes

3.

Mark Up of proposed Renewed Facility License and Technical Specification pages Moore, Dennis M

Digitally signed by Moore, Dennis M Date: 2025.06.27 08:39:23

-04'00'

U.S. Nuclear Regulatory Commission Page 3 License Amendment Request - New Fuel Receipt Docket No. 50-289 June 27, 2025 cc:

NRC Regional Administrator - Region I NRC Director, NRR - DORL NRC Deputy Director, NRR - DORL NRC Project Manager, NRR-DORL - CCEC NRC Project Manager, NMSS - CCEC Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection Chairman, Board of County Commissioners of Dauphin County Chairman, Board of Supervisors of Londonderry Township

ATTACHMENT 1 Summary of Regulatory Commitments Crane Clean Energy Center Renewed Facility License No. DPR-50

License Amendment Request New Fuel Receipt Page 1 Summary of Regulatory Commitments Summary of Regulatory Commitments The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRCs information and are not regulatory commitments.)

COMMITMENT COMMITTED DATE COMMITMENT TYPE One-Time Action (Yes/No)

Programmatic (Yes/No)

CEG will revise procedures governing the processes for the control of movement and storage of reactor fuel or sealed neutron sources for reactor startup to state that reactor fuel or sealed neutron sources for reactor startup shall not be placed in Region II of Spent Fuel Pool A until Permanently Defueled Technical Specification 5.1.2 is revised and the applicable guidance of Renewed Facility Operating License Technical Specification 5.4.2 is restored by NRC approval.

Prior to Receipt of New Fuel Yes No

ATTACHMENT 2 Evaluation of Proposed Changes Crane Clean Energy Center Renewed Facility License No. DPR-50

License Amendment Request New Fuel Receipt Page 1 of 11 Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION This license amendment request (LAR) proposes to amend Renewed Facility License (RFL)

No. DPR-50 for the Crane Clean Energy Center (Crane) to revise license condition 2.b.(2) to include receipt of new reactor fuel and new sealed neutron sources for reactor startup and to restore Technical Specification (TS) 5.4.1 applicable to New Fuel Storage Facilities.

On November 4, 2024, CEG submitted a letter (Reference 1) to the NRC proposing a regulatory path to reauthorize power operations at Crane1 consistent with IMC 2562, Light-Water Reactor Inspection Program for Restart of Reactor Facilities Following Permanent Cessation of Power Operations. The regulatory pathway letter provides a discussion of the steps CEG contemplates for obtaining NRC authorization for resumption of power operations.

This proposed amendment of the RFL is necessary to support receipt of new reactor fuel and new sealed neutron sources for reactor startup prior to authorization of power operations.

Crane is currently licensed to receive, possess and use source, byproduct and special nuclear material as stated in license condition 1.i of the Crane RFL. However, currently, limitations regarding source, byproduct and special nuclear material are stated in license condition 2.b.(2). The license condition limits the possession of reactor fuel and sealed neutron sources for reactor startup to those previously used. The proposed amendment will revise license condition 2.b.(2) to allow receipt and possession of new reactor fuel and new sealed neutron sources for reactor startup as shown below.

Additionally, Crane TSs currently address Spent Fuel Storage Facilities only. The proposed amendment will restore TSs applicable to New Fuel Storage Facilities in support of receiving and storing new reactor fuel and new sealed neutron sources for reactor startup.

Prior to receiving new fuel and new sealed neutron sources for reactor startup, and independent of this LAR, new fuel storage facilities and support system functionality will be restored. The restoration activities will include systems which support receipt and storage of new reactor fuel, such as Spent Fuel Pool Cooling and Fuel Handling systems. Updates to the Defueled Safety Analysis Report (DSAR) for these systems will be made in accordance with 10 CFR 50.59.

2.0 DETAILED DESCRIPTION Crane commenced commercial operation in 1974 and was granted initial license renewal in 2009 to extend the Operating License into 2034.

On June 20, 2017, in accordance with 10 CFR 50.82(a)(1)(i), CEG2 submitted a letter certifying the companys decision to permanently cease power operations at Crane (Reference 2).

1 At that time, Crane was named Three Mile Island Nuclear Station, Unit 1. NRC approved Amendment No. 306 to the Renewed Facility License to reflect the name change to Christopher M. Crane Clean Energy Center on May 13, 2025 (Reference 9). While some actions or events referred to in this document occurred under the name Three Mile Island Nuclear Station, Unit 1 or TMI-1, for clarity, Crane will be used as the name of the facility.

2 At that time, CEG was named Exelon Generation Company, LLC. NRC approved the indirect transfer of licenses associated with Exelon Generation Companys spinoff from Exelon Corporation on November 16, 2021 (Reference 10). This included changing the name of Exelon Generation Company, LLC to Constellation Energy Generation, LLC, while remaining the same legal entity and licensed owner and operator of Three Mile Island, Unit 1. While some actions referred to in this document were submitted under the name Exelon or Exelon Generation Company, for clarity, CEG or Constellation will be used as the name of the licensee.

License Amendment Request New Fuel Receipt Page 2 of 11 Evaluation of Proposed Changes On September 20, 2019, the Crane reactor was shut down as communicated in the 10 CFR 50.82(a)(1)(i) certification letter.

On September 29, 2019, in accordance with 10 CFR 50.82(a)(1)(ii), CEG submitted a letter certifying that all fuel had been permanently removed from the Crane reactor vessel and placed in the Spent Fuel Pool (Reference 3). Per 10 CFR 50.82(a)(2), upon docketing the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel, operation of the reactor or emplacement or retention of fuel into the reactor vessel was no longer authorized by the 10 CFR Part 50 license.

On July 27, 2022, Crane certified that all spent fuel had been removed from the spent fuel pools and placed in storage in the Independent Spent Fuel Storage Installation (ISFSI).

(Reference 4)

This LAR is limited to receipt, possession and storage only, and is bounded by 10 CFR 50.82(a)(2) and the aforementioned docketed certifications.

CEG is submitting proposed revisions to the RFL and its appendix, the Permanently Defueled Technical Specifications (PDTS) which, if approved, would authorize CEG to receive new reactor fuel and new sealed neutron sources for reactor startup and restore the TS applicable to storage of new reactor fuel as shown below.

Current License Condition 2.b.(2)

(Amendment No. 306)

Proposed License Condition 2.b.(2)

Constellation Energy Generation, LLC pursuant to the Act and 10 CFR Parts 30, 40 and 70 to possess at any time any byproduct, source and special nuclear material used previously as reactor fuel, sealed neutron sources used previously for reactor startup, as fission detectors, and sealed sources for reactor instrumentation and to possess and use at any time any byproduct, source and special nuclear material as sealed sources for radiation monitoring equipment calibration in amounts as required; Constellation Energy Generation, LLC pursuant to the Act and 10 CFR Parts 30, 40 and 70 to receive and possess at any time any byproduct, source and special nuclear material used previously as reactor fuel, sealed neutron sources used previously for reactor startup, as fission detectors, and sealed sources for reactor instrumentation and to possess and use at any time any byproduct, source and special nuclear material as sealed sources for radiation monitoring equipment calibration in amounts as required; BASIS: The current license condition limits possession of reactor fuel and sealed neutron sources for reactor startup to previously used reactor fuel and previously used sealed neutron sources. The proposed license condition allows for receipt and possession of new nuclear fuel and new sealed neutron sources for startup by removing used previously as shown above.

Proposed Technical Specification 5.4.1 5.4 NEW AND SPENT FUEL STORAGE FACILITIES Applicability Applies to storage facilities for new and spent fuel assemblies.

License Amendment Request New Fuel Receipt Page 3 of 11 Evaluation of Proposed Changes Objective To assure that both new and spent fuel assemblies will be stored in such a manner that an inadvertent criticality could not occur.

Specification 5.4.1 NEW FUEL STORAGE

a. New fuel will normally be stored in the new fuel storage vault or spent fuel pools.

For the new fuel storage vault, the fuel assemblies are stored in racks in parallel rows, having a nominal center to center distance of 21-1/8 inches in both directions. The spacing in the new fuel storage vault is sufficient to maintain Keff less than 0.95 based on storage of fuel assemblies in clean unborated water or less than 0.98 based on storage in an optimum hypothetical low density moderator (fog or foam) for fuel assemblies with a nominal enrichment of 5.0 weight percent U235. When fuel is being stored in the new fuel storage vault, twelve (12) storage locations (aligned in two rows of six locations each; transverse row numbers four and eight) must be left vacant of fissile or moderating material to provide sufficient neutron leakage to satisfy the NRC maximum allowable reactivity value under the optimum low moderator density condition.

For Spent Fuel Pool "A", the fuel assemblies are stored in racks in parallel rows, having a nominal center to center distance of 11.1 inches in both directions for the Region I racks and 9.2 inches in both directions for the Region II racks. The spacing in the Spent Fuel Pool "A" storage locations for both Region I and II is adequate to maintain Keff less than 0.95. Region I will store fuel with a maximum 5.0 percent initial enrichment. Region II will store new fuel with low enrichment. When fuel is being moved in or over the Spent Fuel Storage Pool "A" and fuel is being stored in the pool, a boron concentration of at least 600 ppmb must be maintained to meet the NRC maximum allowable reactivity value under the postulated accident condition.

For Spent Fuel Pool "B", the fuel assemblies are stored in racks in parallel rows, having nominal center to center distance of 13-5/8 inches in both directions. This spacing is sufficient to maintain a Keff less than 0.95 based on fuel assemblies with a maximum enrichment of 4.37 weight percent U235.

When fuel is being moved in or over the Spent Fuel Storage Pool "B" and fuel is being stored in the pool, a boron concentration of at least 600 ppmb must be maintained to meet the NRC maximum allowable reactivity value under the postulated accident condition.

b. Deleted New fuel may also be stored in shipping containers.

c. New fuel may also be stored in shipping containers.

License Amendment Request New Fuel Receipt Page 4 of 11 Evaluation of Proposed Changes BASIS: This TS is being restored to be consistent with the TS as previously approved by the NRC in Amendment No. 170 with three (3) minor editorial changes as shown in Attachment 3, Markup of proposed Renewed Facility License and Technical Specification pages.

1. The statement boron concentration of at least 600 ppmb is revised to boron concentration of at least 600 ppm to eliminate confusion and redundancy.

2. The word to is added to the final sentence of TS 5.4.1 a. between maintained and meet to resolve an editorial error.

3. The text of TS 5.4.1 b. was previously deleted but paragraph b. remained in place and with the word Deleted. With the proposed amendment, paragraph b. is revised to reflect previous paragraph c. and paragraph c. is being removed.

Additionally, TS 5.3 does not exist in the PDTS. In anticipation of the restoration of the ORLB, TS 5.3 is being added as a place holder to maintain TS numbering consistent with the most recently approved Operating TSs through Amendment No. 294.

The storage restrictions of TS 5.4.1 applicable to the A and B spent fuel pools are implemented through procedure controls for generating fuel move sequence directions.

However, specific guidance on new fuel with low enrichment, as applied to storage in Region II of the A Spent Fuel Pool, was previously provided in TS 5.4.2 of the RFOL relative to new and spent fuel. As this LAR does not restore TS 5.4.2, no new reactor fuel will be stored in Region II of the A Spent Fuel Pool prior to revising the PDTS 5.1.2 and reinstating TS 5.4.2.

This will be controlled by the following commitment.

Commitment: CEG will revise procedures governing the processes for the control of movement and storage of reactor fuel or sealed neutron sources for reactor startup to state that reactor fuel or sealed neutron sources for reactor startup shall not be placed in Region II of Spent Fuel Pool A until Permanently Defueled Technical Specification 5.1.2 is revised and the applicable guidance of Renewed Facility Operating License Technical Specification 5.4.2 is restored by NRC approval.

3.0 TECHNICAL EVALUATION

The technical justification for this LAR is based on demonstrating continued compliance with regulations applicable to physical protection of the new reactor fuel and new sealed neutron sources for reactor startup as well as criticality requirements for new reactor fuel.

Crane is currently licensed under 10 CFR Part 70 to receive, possess, and store special nuclear material. Protection of this special nuclear material is required as described in 10 CFR 73.67. The proposed amendment will not change these requirements.

10 CFR 73.67 protection requirements are based, in part, on the strategic significance of the quantity and enrichment of the special nuclear material in question. The new reactor fuel to be stored at Crane will contain greater than 10,000 grams of uranium-235 (contained in uranium enriched above natural levels but less than 10 percent in the U-235 isotope). Thus, the requirements for Special Nuclear Material of Low Strategic Significance are applicable to receipt and possession of new reactor fuel.

10 CFR 70.24 provides criticality accident requirements for licensees in possession of quantities of special nuclear material in excess of specified amounts. In accordance with

License Amendment Request New Fuel Receipt Page 5 of 11 Evaluation of Proposed Changes 10 CFR 70.24(d)(1), Crane will comply with the requirements of 10 CFR 50.68 for compliance with criticality requirements associated with receipt of new reactor fuel as discussed below.

Specifically, as demonstrated in References 5 and 6, by maintaining the design features as described in proposed TS 5.4.1, a criticality accident is not a credible event.

3.1 Revision to License Condition 2.b.(2)

The NRC divides special nuclear material into three (3) categories according to risk and potential for its direct use in a clandestine fissile explosive or for use in the production of nuclear material for use in a fissile explosive. The NRC defines the lowest risk category as Special nuclear material of low strategic significance or Category III. New (unirradiated) fuel falls into this category as defined in 10 CFR 70.4. Specifically, 10,000 grams or more of uranium-235 (contained in uranium enriched above natural but less than 10 percent in the U-235 isotope). As such, the requirements of 10 CFR 73.67, Licensee fixed site and in-transit requirements for the physical protection of special nuclear material of moderate and low strategic significance are applicable.

Compliance with 10 CFR 73.67 for existing on-site special nuclear material is discussed in CEGs response to the NRCs Request for Additional Information (RAI), dated May 4, 2022 (Reference 7), regarding a revision to the Three Mile Island Nuclear Station Independent Spent Fuel Storage Installation (ISFSI) Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan. In the response, CEG clarified that 10 CFR 73.67 compliance is described in the Materials Security Plan which was implemented along with the ISFSI Security Plan.

The Materials Security Plan is a licensee-controlled document which describes both the material that requires protection as well as the protection strategy for the material. CEG will revise the Materials Security Plan to incorporate protection of new reactor fuel and new sealed neutron sources for reactor startup prior to the receipt of new fuel.

3.2 Restoration of Technical Specification 5.4.1 Technical Specifications are required by 10 CFR 50.36. Crane maintains custom technical specifications. Section 5.0 for Crane is Design Features. From 10 CFR 50.36, Design features to be included are those features of the facility such as materials of construction and geometric arrangements, which, if altered or modified, would have a significant effect on safety and are not covered in categories described in paragraphs (c) (1), (2), and (3) of this section.

TS 5.4.1 establishes, as required design features, the conditions of the A and B Spent Fuel Pools as well as the New Fuel Storage Vault, necessary for compliance with 10 CFR 50.68.

TS 5.4.1 requirements are being restored consistent with the operating TS as approved by Amendment No. 170 (Reference 8) with minor editorial changes.

Compliance with 10 CFR 50.68, for the latest received new reactor fuel type, MARK-B-HTP, is demonstrated in References 5 and 6.

CEG has contracted Framatome to provide the same fuel type that was in use when TS 5.4.1 was last applicable. A comparison of the fuel received and stored prior to shut down with the fuel to be received and stored with the proposed amendment was completed and confirmed the applicability of References 5 and 6 to the new fuel to be received.

License Amendment Request New Fuel Receipt Page 6 of 11 Evaluation of Proposed Changes

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.1.1 10 CFR 73.67 Licensee fixed site and in-transit requirements for the physical protection of special nuclear material of moderate and low strategic significance.

10 CFR 73.67 Requirements:

(a) General performance objectives.

(1) Each licensee who possesses, uses or transports special nuclear material of moderate or low strategic significance shall establish and maintain a physical protection system that will achieve the following objectives:

(i) Minimize the possibilities for unauthorized removal of special nuclear material consistent with the potential consequences of such actions; and (ii) Facilitate the location and recovery of missing special nuclear material Compliance: Crane maintains, as a licensee-controlled program, the Materials Security Plan for special nuclear material. This plan implements the actions necessary to meet the stated objectives of 10 CFR 73.67(a)(1). The plan will be revised to incorporate the receipt and possession of new reactor fuel and new sealed neutron sources for reactor startup as part of implementation activities for this LAR.

4.1.2 10 CFR 50.68 Criticality accident requirements (a) Each holder of a construction permit or operating license for a nuclear power reactor issued under this part or a combined license for a nuclear power reactor issued under Part 52 of this chapter, shall comply with either 10 CFR 70.24 of this chapter or the requirements in paragraph (b) of this section.

[]

(2) The estimated ratio of neutron production to neutron absorption and leakage (k-effective) of the fresh fuel in the fresh fuel storage racks shall be calculated assuming the racks are loaded with fuel of the maximum fuel assembly reactivity and flooded with unborated water and must not exceed 0.95, at a 95 percent probability, 95 percent confidence level. This evaluation need not be performed if administrative controls and/or design features prevent such flooding or if fresh fuel storage racks are not used.

(3) If optimum moderation of fresh fuel in the fresh fuel storage racks occurs when the racks are assumed to be loaded with fuel of the maximum fuel assembly reactivity and filled with low-density hydrogenous fluid, the k-effective corresponding to this optimum moderation must not exceed 0.98, at a 95 percent probability, 95 percent confidence level. This evaluation need not be performed if administrative controls and/or design features prevent such moderation or if fresh fuel storage racks are not used.

Compliance: Crane will establish, as a TS, the design features described in TS 5.4.1 necessary to ensure k-effective (keff) meets regulatory requirements.

License Amendment Request New Fuel Receipt Page 7 of 11 Evaluation of Proposed Changes The new fuel, as discussed above, is Mark-B-HTP fuel. Crane began using Mark-B-HTP type fuel assemblies in 2007 and continued to use this fuel type until shutdown in 2019. The criticality analysis applicable to the 2019 Mark-B-HTP fuel remains valid for the Mark-B-HTP fuel to be received in 2026 as these two fuel lots are neutronically equivalent based on use of identical fuel rod designs, uranium loading, and lattice geometry.

From Reference 5, the design features of the Mark-B-HTP fuel, which are relevant to the fuel pool criticality analysis, include Pellet Diameter, Cladding Inner and Outer diameter, Cladding material, Fuel Density, Number of Guide Tubes (GT) and Instrument Tubes (IT), GT and IT Inner and Outer Diameter, Fuel Rod Array, Number of Fuel Rods per assembly, Fuel Rod Pitch, and Fuel Rod Enrichment.

The values for these parameters were reviewed and found to be the same in that the values and tolerances for the new fuel are bounded by the values and tolerances for the fuel previously evaluated in references 5 and 6.

4.2 Precedent As pertains to protection of special nuclear material in the form of new reactor fuel, the NRC documented, in a recent exemption for Southern Nuclear Operating Company, that 10 CFR 73.67 provides adequate guidance for protection of new reactor fuel.

[] unirradiated reactor fuel poses no significant risk to the public health and safety and protecting it in accordance with 10 CFR 73.67 would not be inimical to the common defense and security. (86 Fed. Reg 67734 (Nov 29, 2021))

4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.92, CEG has concluded that the proposed changes do not involve a significant hazards consideration (SHC). The basis for the conclusion that the proposed changes do not involve a SHC is as follows:

1. The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

The receipt of new fuel results in the need for compliance with 10 CFR 50.68 Criticality accident requirements. As demonstrated in References 5 and 6, a criticality accident is not a credible event based on the design features described in proposed TS 5.4.1. Additionally, the proposed amendment does not result in a change to the current storage requirements for spent nuclear fuel as defined in TS 5.2.1 which prevents storage of spent fuel in the spent fuel pools. All spent nuclear fuel will remain in the dry cask storage systems on the ISFSI pad.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. The proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

License Amendment Request New Fuel Receipt Page 8 of 11 Evaluation of Proposed Changes The receipt of new fuel results in the need for compliance with 10 CFR 50.68, Criticality accident requirements. As demonstrated in References 5 and 6, a criticality accident is not a credible event based on the design features described in proposed TS 5.4.1. Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated.

3. The proposed changes do not involve a significant reduction in the margin of safety.

Margin of safety is associated with confidence in the ability of the fission product barriers (i.e.,

fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public.

As discussed above, the receipt of new fuel results in the need for compliance to 10 CFR 50.68 Criticality accident requirements. As demonstrated in References 5 and 6, a criticality accident is not a credible event based on the design features described in proposed TS 5.4.1. The proposed amendment does not result in a change to the current storage and protection requirements for spent nuclear fuel. Specifically, all spent nuclear fuel will remain in the current dry cask storage systems at the ISFSI.

Additionally, the proposed changes will not relax any criteria used to establish safety limits, will not relax any safety system settings, and will not relax the bases for any limiting conditions of operation. Therefore, these proposed changes do not involve a significant reduction in the margin of safety.

Based on the above, CEG concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(b), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4 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 proposed amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

CEG 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 10 CFR Part 20, or 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, CEG has determined that the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). The proposed amendment also authorizes possession of additional sealed sources, beyond those authorized by the current license, which fits within the categorical exclusion set forth in 10 CFR 51.22(c)(14)(vii).

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

License Amendment Request New Fuel Receipt Page 9 of 11 Evaluation of Proposed Changes Alternatively, if the proposed action is not eligible for categorical exclusions, CEG has evaluated the environmental impacts of the proposed licensing action and concluded that approving the requested action will not have a significant impact on the quality of the human environment.

The requested action, which would allow CEG to receive new, unirradiated, reactor fuel and new sealed neutron sources for reactor startup, results in a change to the inventory of byproduct, source and special nuclear material currently authorized for possession at Crane.

The requested action does not authorize the use of the new, unirradiated fuel or sealed neutron sources, in the reactor, and therefore, the impact to the environment is limited to storage of the new reactor fuel and sealed neutron sources.

As discussed above, the possession of new reactor fuel results in the requirement for a criticality accident analysis. The analysis referenced demonstrates that a criticality accident is not a credible event and therefore, new reactor fuel is not a potential radiological accident source.

a)

Environmental Impacts of the Proposed Action The radiological exposure to station personnel due to receipt and transfer of new reactor fuel and sealed neutrons sources is consistent with, and in many cases, less than the exposure received conducting other activities currently authorized at Crane. Controls for handling radioactive material, following standard ALARA principles, are in place and are applicable to the new sealed neutron sources. The proposed activity does not increase the allowable radiological exposure to the Crane workforce and therefore, the maximum allowable radiological impact on station personnel is not changed by including the proposed action with currently authorized activities.

There is no decay heat associated with new reactor fuel or new sealed neutron sources, accordingly there is no thermal interaction with the environment.

There are no gaseous, liquid, or solid effluents (radiological or non-radiological), or land disturbances associated with the proposed action. Additionally, as shown above, there is no significant increase in the radiological exposure to the Crane workforce and no increase in radiological exposure to members of the public. Therefore, approval of the requested action has no significant impact on the environment.

Additionally, the potential radiological and nonradiological environmental impacts of the transportation and storage of fresh nuclear fuel have been evaluated in detail in: (1) the 2024 license renewal GEIS3 based, in part, on the generic impacts provided in 10 CFR 51.51(b),

Table S-3, Table of Uranium Fuel Cycle Environmental Data, and in 10 CFR 51.52(c), Table S-4, Environmental Impact of Transportation of Fuel and Waste to and from One Light-Water-Cooled Nuclear Power Reactor; (2) NUREG-2266, Evaluation of Accident Tolerant Fuels; and (3) the 2009 SEIS4 for license renewal of Three Mile Island Nuclear Station, Unit 1. These analyses, which are bounding of the proposed action here, demonstrate that the 3 NUREG-1437, Revision 2 Generic Environmental Impact Statement for License Renewal of Nuclear Plants (Published August 2024) 4 NUREG-1437 Supplement 37, Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 37 Regarding Three Mile Island Nuclear Station, Unit 1 Final Report (Published June 2009)

License Amendment Request New Fuel Receipt Page 10 of 11 Evaluation of Proposed Changes environmental impacts of the transportation and storage of fresh nuclear fuel are not significant. CEG is not aware of any new and significant information that would alter that conclusion.

b)

Adverse Environmental Effects Which Cannot be Avoided Should the Proposed Action be Approved As there are no significant environmental impacts, above and beyond the impacts of currently authorized activities, associated with approval of the requested action, there are no adverse environmental effects which cannot be avoided should the requested action be approved.

c)

Alternative to the Proposed Action In addition to the proposed licensing action, alternative action has been considered.

Specifically, CEG evaluated the no-action alternative, whereby the LAR is not approved.

Under that alternative, existing license conditions, 1.i and 2.b.(2), would continue to authorize the receipt, possession and storage of byproduct, source and special nuclear material at Crane that has been used previously, but no new reactor fuel and no new sealed neutron sources would be received and stored at Crane.

d)

Environmental Effects of the Alternatives to the Proposed Action There are no new environmental impacts associated with the alternative to the proposed action which would maintain the status quo. By way of comparison, the environmental impacts of the proposed action and the no-action alternative would be similar. That is because there is no meaningful difference in impacts from possession and storage of materials that have been used previously versus those that have not.

5.1 Environmental

Conclusion:

CEG has confirmed that the effects of the proposed amendment do not involve 1) a significant hazards consideration, 2) a significant change in the types of or significant increase in the amounts of any effluents that may be released offsite, or 3) a significant increase in the individual or cumulative occupational radiation exposure. Consequently, the proposed changes will not have a significant effect on the quality of the human environment.

License Amendment Request New Fuel Receipt Page 11 of 11 Evaluation of Proposed Changes

6.0 REFERENCES

1. Constellation Energy Generation, LLC letter to U.S. Nuclear Regulatory Commission, Regulatory Path to Reauthorize Power Operations, dated November 4, 2024 (ADAMS Accession No. ML24310A104)

2. Exelon Generation Company, LLC letter to U.S. Nuclear Regulatory Commission, Certification of Permanent Cessation of Power Operations for Three Mile Island Nuclear Station, Unit 1, dated June 20, 2017 (ADAMS Accession No. ML17171A151).

3. Exelon Generation Company, LLC letter to U.S. Nuclear Regulatory Commission, Certification of Permanent Removal of Fuel from the Reactor Vessel for Three Mile Island Nuclear Station, Unit 1, dated September 26, 2019 (ADAMS Accession No. ML19269E480)

4. Constellation Energy Generation, LLC letter to U.S. Nuclear Regulatory Commission, Certification of Permanent Removal of All Spent Fuel Assemblies from the Spent Fuel Pool, dated July 27, 2022 (ADAMS Accession No. ML22208A093)

5. Holtec International Report No. HI-2002554, Rev. 1, Criticality Safety Evaluation of TMI Fuel Storage Facilities with New B&W Fuel, March 23, 2001

6. Engineering Design Change Package TM-06-01135, Implementation of Mark-B-HTP Fuel Design, August 31, 2007

7. Constellation Energy Generation, LLC letter to U.S. Nuclear Regulatory Commission, Response to Request for Additional Information, License Amendment Request - Revise Three Mile Island Nuclear Station License in Support of Independent Spent Fuel Storage Installation (ISFSI) Only Security Plan, dated May 6, 2022 (Accession No. ML22126A140)

8. U.S. Nuclear Regulatory Commission Letter to GPU Nuclear Corporation - Issuance of Amendment (TAC No. M84596) [No. 170 to Facility Operating License No. DPR-50],

dated February 17, 1993 (ADAMS Accession No. ML003765905)

9. U.S. Nuclear Regulatory Commission Letter to Constellation Energy Generation, LLC Three Mile Island Nuclear Station, Unit 1 - Issuance of Amendment No. 306 RE: Facility Name Change from Three Mile Island Nuclear Station, Unit 1 to Christopher M. Crane Clean Energy Center (EPID L-2025-LLA-0008), dated May 13, 2025 (ADAMS Accession No. ML25100A006)

10. Constellation Energy Generation, LLC letter to U.S. Nuclear Regulatory Commission, Notification of Completion of License Transfer and Request to Continue Processing Pending NRC Actions Previously Requested by Exelon Generation Company, LLC, dated February 1, 2022 (ADAMS Accession No. ML22032A333)

ATTACHMENT 3 Mark Up of proposed Renewed Facility License and Technical Specification pages Crane Clean Energy Center Renewed Facility License No. DPR-50 Amendment No. [XXX]

Renewed License No. DPR-50 CONSTELLATION ENERGY GENERATION, LLC Christopher M. Crane Clean Energy Center DOCKET NO. 50-289 RENEWED FACILITY LICENSE Renewed License No. DPR-50

1. The Nuclear Regulatory Commission (the Commission) having found that:

a. The application for a renewed license filed by the applicant complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter 1 and all required notifications to other agencies or bodies have been duly made;

b. DELETED

c. The facility will be maintained in conformity with the application, as amended, the provisions of the Act and the rules and regulations of the Commission;

d. There is a reasonable assurance: (1) that the activities authorized by this renewed license can be conducted without endangering the health and safety of the public, and (2) that such activities will be conducted in compliance with the rules and regulations of the Commission;

e. Constellation Energy Generation, LLC is technically and financially qualified to engage in the activities authorized by this renewed operating license in accordance with the rules and regulations of the Commission;

f.

Constellation Energy Generation, LLC has satisfied the applicable provisions of 10 CFR Part 140, Financial Protection Requirements and Indemnity Agreements, of the Commission's regulations;

g. The issuance of this renewed license will not be inimical to the common defense and security or to the health and safety of the public;

h. After weighing the environmental, economic, technical, and other benefits of the facility against environmental costs and considering available alternatives, the issuance of Renewed Facility License No. DPR-50 is in accordance with 10 CFR Part 50, Appendix D, of the Commission's regulations and all applicable requirements of said Appendix D have been satisfied;

i.

The receipt, possession, and use of source, byproduct and special nuclear material as authorized by this license will be in accordance with the Commissions regulations in 10 CFR Parts 30, 40, and 70, including 10 CFR Section 30.33, 40.32, 70.23 and 70.31.

j.

DELETED Amendment No. [XXX]

Renewed License No. DPR-50

2. Renewed Facility License No. DPR-50 is hereby issued to Constellation Energy Generation, LLC to read as follows:

a. This renewed license applies to the Christopher M. Crane Clean Energy Center (Crane Clean Energy Center or CCEC), a pressurized water reactor and associated equipment (the facility), owned by Constellation Energy Generation, LLC. The facility is located in Dauphin County, Pennsylvania, and is described in the Updated Final Safety Evaluation Report (UFSAR) as supplemented and amended and the Environmental Report as supplemented and amended.

b. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses:

(1)

Constellation Energy Generation, LLC pursuant to Section 104b of the Act and 10 CFR Part 50, Licensing of Production and Utilization Facilities, to possess and use the facility as required for fuel storage in accordance with the procedures and limitations set forth in this renewed license; (2)

Constellation Energy Generation, LLC pursuant to the Act and 10 CFR Parts 30, 40 and 70 to receive and possess at any time any byproduct, source and special nuclear material used previously as reactor fuel, sealed neutron sources used previously for reactor startup, as fission detectors, and sealed sources for reactor instrumentation and to possess and use at any time any byproduct, source and special nuclear material as sealed sources for radiation monitoring equipment calibration in amounts as required; (3)

Constellation Energy Generation, LLC, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess at either CCEC or TMl-2, and use in amounts as required for CCEC any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis, testing, instrument calibration, or associated with radioactive apparatus or components. Other than radioactive apparatus and components to be used at TMI Unit 2 in accordance with the TMl-2 License, the radioactive apparatus and components that may be moved from CCEC to TMI Unit 2 under this provision shall be limited to: (1) outage-related items (such as contaminated scaffolding, tools, protective clothing, portable shielding and decontamination equipment);

and (2) other equipment belonging to CCEC when storage of such equipment at TMl-2 is deemed necessary for load handling or contamination control considerations; (4)

Constellation Energy Generation, LLC, pursuant to the Act and 10 CFR Parts 30 and 70, to possess at the CCEC or TMI Unit 2 site, but not separate, such byproduct and special nuclear materials that were produced by the operation of either unit. Radioactive waste may be moved from TMI Unit 2 to CCEC under this provision for collection, processing (including decontamination),

packaging, and temporary storage prior to disposal. Radioactive waste that may be moved from CCEC to TMI Unit 2 under this provision shall be limited to:

(1) dry active waste (DAW) temporarily moved to TMI Unit 2 during waste collection activities, and (2) contaminated liquid contained in shared system piping and tanks. Radioactive waste that may be moved from CCEC to TMI Unit 2 under this provision shall not include spent fuel, spent resins, filter Amendment No. [XXX]

Renewed License No. DPR-50 sludge, evaporator bottoms, contaminated oil, or contaminated liquid filters.

The storage of radioactive materials or radwaste generated at TMI Unit 2 and stored at CCEC shall not result in a source term that, if released, would exceed that previously analyzed in the UFSAR in terms of off-site dose consequences.

The storage of radioactive materials or radwaste generated at CCEC and stored at TMI Unit 2 shall not result in a source term that, if released, would exceed that previously analyzed in the PDMS SAR for TMI Unit 2 in terms of off-site dose consequences.

c. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

DELETED (2)

Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. [XXX], are hereby incorporated in the license. Constellation Energy Generation, LLC shall maintain the facility in accordance with the Permanently Defueled Technical Specifications (PDTS).

(3)

Physical Protection Constellation Energy, LLC shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to 10 CFR 72.212(b)(9) and the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans,1 submitted by letter dated April 29, 2021 (ML21145A183), as supplemented on May 6, 2022 (ML22126A140) and May 26, 2022 (ML22146A349 (nonpublic)) is titled: Three Mile Island Nuclear Station Independent Spent Fuel Storage Installation Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision

0. This set contains Safeguards Information protected under 10 CFR 73.21.

(4)

DELETED 1 The Training and Qualification Plan and Safeguards Contingency Plan are Appendices to the Security Plan.

Amendment No. [XXX]

Renewed License No. DPR-50 (5)

DELETED (6) lnservice Testing - DELETED (7)

Aircraft Movements - DELETED (8)

Repaired Steam Generators - DELETED (9)

Long Range Planning Program - DELETED Sale and License Transfer Conditions (10) Constellation Energy Generation, LLC shall provide to the Director of the Office of Nuclear Reactor Regulation or the Director of the Office of Nuclear Material Safety and Safeguards, as applicable, a copy of any application, at the time it is filed, to transfer (excluding grants of security interests or liens) from Constellation Energy Generation, LLC to its direct or indirect parent, or to any other affiliated company, facilities for the production, transmission, or distribution of electric energy having a depreciated book value exceeding ten percent (10%) of Constellation Energy Generation, LLCs consolidated net utility plant, as recorded on Constellation Energy Generation, LLCs books of account.

(11) DELETED (12) DELETED (13) DELETED (14) DELETED (15) Constellation Energy Generation, LLC shall take all necessary steps to ensure that the decommissioning trust is maintained in accordance with the application, the requirements of the Order Approving Transfer of License and Conforming Amendment, dated January 8, 2009, and the related Safety Evaluation dated December 23, 2008.

(16) DELETED (17) DELETED (18) DELETED (19) DELETED (20) DELETED (21) DELETED Amendment No. [XXX]

Renewed License No. DPR-50 (22) DELETED

d. This license is effective as of the date of issuance and is effective until the Commission notifies the licensee in writing that the license is terminated.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Eric J. Leeds, Director Office of Nuclear Reactor Regulation

Attachment:

Appendix A, Technical Specifications Date of Issuance: [DATE]

Amendment 11, 72, 129, 137, 142, 150, 155, 173, 278, 297, 298, 300, 304, XXX TABLE OF CONTENTS Section Page TECHNlCAL SPEClFlCATlONS 1.0 - 4.0 DELETED 5.0 DESlGN FEATURES 5-1 5.1 SlTE 5-1 5.2 SPENT FUEL STORAGE FAClLlTlES 5-1 5.2.1 Spent Fuel Storage 5-1 5.3

[SAVE FOR FUTURE USE]

5-1 5.4 NEW AND SPENT FUEL STORAGE FACILITIES 5-1 5.4.1 New Fuel Storage 5-1 5.4.2 Spent Fuel Storage 5-2 6.0 ADMlNlSTRATlVE CONTROLS 6-1 6.1 REPORTING REQUIREMENTS 6-1 6.1.1 Annual Radioactive Effluent Release Report 6-1 6.2 HIGH RADIATION AREA 6-1

5-1 Amendment No. 138, 164, 170, 297, 304, XXX 5.0 DESlGN FEATURES 5.1 SlTE Specification 5.1.1 The description of the Crane Clean Energy Center site, including Exclusion/Restricted Area as defined in 10 CFR 100.3, is located in the Final Safety Analysis Report, as updated.

5.2 SPENT FUEL STORAGE FAClLlTlES Specification 5.2.1 SPENT FUEL STORAGE Spent fuel shall not be stored in the A or B spent fuel pools.

5.3

[SAVE FOR FUTURE USE]

5.4 NEW AND SPENT FUEL STORAGE FACILITIES Applicability Applies to storage facilities for new and spent fuel assemblies Objective To assure that both new and spent fuel assemblies will be stored in such a manner that an inadvertent criticality could not occur.

Specification 5.4.1 NEW FUEL STORAGE

a. New fuel will normally be stored in the new fuel storage vault or spent fuel pools.

For the new fuel storage vault, the fuel assemblies are stored in racks in parallel rows, having a nominal center to center distance of 21-1/8 inches in both directions.

The spacing in the new fuel storage vault is sufficient to maintain Keff less than 0.95 based on storage of fuel assemblies in clean unborated water or less than 0.98 based on storage in an optimum hypothetical low density moderator (fog or foam) for fuel assemblies with a nominal enrichment of 5.0 weight percent U235. When fuel is being stored in the new fuel storage vault, twelve (12) storage locations (aligned in two rows of six locations each; transverse row numbers four and eight) must be left vacant of fissile or moderating material to provide sufficient neutron leakage to satisfy the NRC maximum allowable reactivity value under the optimum low moderator density condition.

5-2 Amendment No. XXX For Spent Fuel Pool "A", the fuel assemblies are stored in racks in parallel rows, having a nominal center to center distance of 11.1 inches in both directions for the Region I racks and 9.2 inches in both directions for the Region II racks. The spacing in the Spent Fuel Pool "A" storage locations for both Region I and II is adequate to maintain Keff less than 0.95. Region I will store fuel with a maximum 5.0 percent initial enrichment. Region II will store new fuel with low enrichment. When fuel is being moved in or over the Spent Fuel Storage Pool "A" and fuel is being stored in the pool, a boron concentration of at least 600 ppmb must be maintained to meet the NRC maximum allowable reactivity value under the postulated accident condition.

For Spent Fuel Pool "B", the fuel assemblies are stored in racks in parallel rows, having nominal center to center distance of 13-5/8 inches in both directions. This spacing is sufficient to maintain a Keff less than 0.95 based on fuel assemblies with a maximum enrichment of 4.37 weight percent U235. When fuel is being moved in or over the Spent Fuel Storage Pool "B" and fuel is being stored in the pool, a boron concentration of at least 600 ppmb must be maintained to meet the NRC maximum allowable reactivity value under the postulated accident condition.

b. Deleted New fuel may also be stored in shipping containers.

c. New fuel may also be stored in shipping containers.

5.4.2 SPENT FUEL STORAGE

a. See Specification 5.2 SPENT FUEL STORAGE FACILITIES