Text

License Amendment Request 272, Exemption Request - Optimized ZIRLO Fuel Rod Cladding
	ML13155A239
Person / Time
Site:	Point Beach
Issue date:	06/04/2013
From:	Meyer L; Point Beach
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NRC 2013-0051, LAR 272
	Download: ML13155A239 (30)
	v • d • e

June 4, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Units 1 and 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 License Amendment Request 272 Exemption Request-Optimized ZIRLOTM Fuel Rod Cladding NEXT era ENERGY~

~

NRC 2013-0051 10 CFR 50.90 Pursuant to 10 CFR 50.90, NextEra Energy Point Beach, LLC (NextEra) hereby requests to amend renewed Facility Operating Licenses DPR-24 and DPR-27 for Point Beach Nuclear Plant (PBNP), Units 1 and 2, respectively. The proposed amendment would revise the PBNP Technical Specifications (TS) 4.2.1, "Fuel Assemblies," to add Optimized ZIRLO' to the approved fuel rod cladding materials and TS 5.6.4, "Core Operating Limits Report (COLR)," to add Westinghouse Electric Company LLC (Westinghouse) topical report WCAP-12610-P-A &

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

In addition, the proposed amendment would require exemption, pursuant to 10 CFR 50.12.

Next Era 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 ZIRLOTM fuel rod cladding in future core reload applications for Point Beach Units 1 and 2. This exemption request is included as Attachment 1 to enclosure of this letter.

The Enclosure provides a detailed description and analysis of the proposed changes. to the Enclosure provides an Exemption Request to portions of 10 CFR 50.46 and 10 CFR Part 50 Appendix K. Attachment 2 to the Enclosure provides the markups of TS pages showing the proposed changes.

Approval of the proposed amendment is requested by May 31, 2014. NextEra will implement the amendment within 120 days of Commission Approval.

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

The proposed TS changes have been reviewed by the Plant Operations Review Committee.

NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241

Document Control Desk Page 2 In accordance with 10 CFR 50.91, a copy of this letter is being provided to the designated Wisconsin Official.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on June 4, 2013 Very truly yours, NextEra Energy Point Beach, LLC Enclosure cc:

Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW

NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST 272 EXEMPTION REQUEST-OPTIMIZED ZIRLO' FUEL ROD CLADDING ENCLOSURE 1

1.0 2.0 2.1 3.0 4.0 4.1 4.2 4.3 4.4 5.0 6.0 7.0 1

2 TABLE OF CONTENTS LICENSE AMENDMENT REQUEST 272 EXEMPTION REQUEST-OPTIMIZED ZIRLO ' FUEL ROD CLADDING SECTION TITLE PAGE Cover Sheet 1

Table of Contents 2

Summary Description 3

Detailed Description 3

Proposed Changes 3

Technical Evaluation 5

Regulatory Evaluation 9

Applicable Regulatory Requirements/Criteria 9

Precedent 10 List of Commitments 10 No Significant Hazards Consideration Determination 11 Environmental Consideration 12 Conclusions 13 References 13 ATTACHMENTS Total Pages Request for Exemption from the Provisions of 10 CFR 5

50.46 & 10 CFR Part 50 Appendix K to Allow Use of Optimized ZIRLO' Fuel Cladding Technical Specification Markups 5

2

1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Next Era Energy Point Beach, LLC (NextEra) hereby requests to amend renewed Facility Operating Licenses DPR-24 and DPR-27 for Point Beach Nuclear Plant (PBNP), Units 1 and 2, respectively,. The proposed amendment would revise Technical Specification (TS) 4.2.1, "Fuel Assemblies," to add Optimized ZIRLO' to the approved fuel rod cladding materials and TS 5.6.4 "Core Operating Limits Report (COLR)," to add Westinghouse Electric Company LLC (Westinghouse) topical report WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO'," to the analytical methods used to determine the core operating limits previously reviewed and approved by the Nuclear Regulatory Commission (NRC).

In addition, the proposed amendment would require exemption, pursuant to 10 CFR 50.12. NextEra 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' fuel rod cladding in future core reload applications for Point Beach Units 1 and 2. This exemption request is included as Attachment 1.

2.0 DETAILED DESCRIPTION Optimized ZIRLO' was developed to meet the needs of longer o~erating cycles with increased fuel discharge burnup and fuel duty. Optimized ZIRLO M fuel cladding is different from standard Zl RLO in two respects: 1) the tin content is lower; and 2) the microstructure is different. This difference in tin content and microstructure leads to differences in some material properties. Optimized ZIRLO' provides a reduced corrosion rate while maintaining the benefits of mechanical strength and resistance to accelerated corrosion from abnormal chemistry conditions. In addition, fuel rod internal pressure (resulting from the increased fuel duty, use of integral fuel burnable absorbers, and corrosion/temperature feedback effects) 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.

2.1 Proposed Changes

1.

TS 4.2.1, Reactor Core, Fuel Assemblies Replace:

The reactor shall contain 121 fuel assemblies. Each assembly shall consist of a matrix of Zircaloy-4 or ZIRLO' fuel rods with an initial composition of natural or slightly enriched uranium dioxide (U02) as fuel material.....

With:

The reactor shall contain 121 fuel assemblies. Each assembly shall consist of a matrix of Zircaloy-4, ZIRLO, or Optimized ZIRLO' fuel rods with an initial 3

composition of natural or slightly enriched uranium dioxide (U02) as fuel material.....

Basis for the change: The proposed change adds Optimized ZIRLO' to the Fuel Assembly Design Features in TS 4.2.1 as an approved fuel rod cladding material for future core reload applications. The ZIRLO trademark (ZIRLO') is changed consistent with the Westinghouse ZIRLO trademark registered as ZIRLO.

2.

TS 5.6.4.b, Core Operating Limits Report (COLR)

Replace:

The approved analytical methods are described in the following documents:

(1)

WCAP-14449-P-A, "Application of Best Estimate Large Break LOCA Methodology to Westinghouse PWR's with Upper Plenum Injection,"

Revision 1, October 1999. (cores containing 422V+ fuel)

(17)

NS-CE-687, Westinghouse to NRC Letter, "Power Distribution Control Analysis," July 16, 1975.

With:

The approved analytical methods are described in the following documents:

(1)

(17)

(18)

(19)

WCAP-14449-P-A, "Application of Best Estimate Large Break LOCA Methodology to Westinghouse PWR's with Upper Plenum Injection,"

Revision 1, October 1999. (cores containing 422V+ fuel)

NS-CE-687, Westinghouse to NRC Letter, "Power Distribution Control Analysis," July 16, 1975.

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

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

Basis for the change: The WCAP-12610-P-A was approved for the 422V+ fuel design change for the Point Beach Units 1 and 2 by Reference 16. This proposed change includes this methodology in the list of COLR methodologies consistent with Reference 16 approval.

The proposed change also adds the previously approved Westinghouse topical report (WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A) to the COLR list of approved analytical method for use in future application of Optimized ZIRLO'.

3. Editorial correction to Reference 14, added "Accident" to the title, and Reference 15, corrected the title and a typo of the WCAP number (9403 to 8403).

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3.0 TECHNICAL EVALUTION Optimized ZIRLO' is described in Westinghouse topical report WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO'," dated July 2006 (Reference 1).

The NRC staff's Safety Evaluation (SE) for Optimized ZIRLO' dated June 10, 2005 requires that licensees comply with the ten conditions and limitations listed within the SE (Reference 2).

The ten conditions and limitations laid out in the NRC's Safety Evaluation for WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A are listed below. NextEra will comply with these conditions and limitations as follows:

1.

Until rulemaking to 10 CFR Part 50 addressing O~timized ZIRLO TM has been completed, implementation of Optimized ZIRLOT fuel clad requires an exemption from 10 CFR 50.46 and 10 CFR Part 50 Appendix K.

RESPONSE: A request for the required exemption from 10 CFR 50.46 and 10 CFR Part 50 Appendix K is provided as Attachment 1 to this enclosure.

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 forCE fuel designs.

RESPONSE: For any fuel using Optimized ZIRLOTM fuel rod cladding, the maximum fuel rod burn up limit for Westinghouse fuel designs will continue to be 62 GWd/MTU until such time that a new fuel rod burn up limit is approved for use.

3.

The maximum fuel rod waterside corrosion, as predicted by the best-estimate model, will [satisfy proprietary limits included in topical report and proprietary version of safety evaluation] of hydrides for all locations of the fuel rod.

RESPONSE: The maximum fuel rod waterside corrosion for fuel using Optimized ZIRLO TM fuel rod cladding will be confirmed to be less than the specified proprietary limits for all locations of the fuel rod. Evaluations are performed to confirm that the appropriate corrosion limits are satisfied as part of the normal reload design process.

4.

All the conditions listed in previous NRC SE approvals for methodologies used for standard ZIRLO and Zircalo¥-4 fuel analysis will continue to be met, except that the use of Optimized ZIRLO M 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 Point Beach Units 1 and 2, this is a current requirement, and confirmation of these conditions is required as part of the normal reload design process.

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5.

All methodologies will be used only within the range for which ZIRLO and Optimized ZIRLO TM data were acceptable and for which the verifications discussed in Addendum 1 and responses to RAis were performed.

RESPONSE: The application of ZIRLO and Optimized ZIRLOTM in approved methodologies will be made consistent with the approach accepted in WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO'," July 2006.

For Point Beach Units 1 and 2, 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 ZIRLO' L TA data from Byron, Calvert Cliffs, Catawba, and Millstone.

i.

Visual ii.

Oxidation of fuel rods iii.

Profilometry iv.

Fuel rod length

v.

Fuel assembly length

b.

Using the standard and Optimized ZIRLO ' database including the most recent L T A 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 ZIRLO' fuel rods must be completed prior to their initial batch loading and prior to the startup of subsequent cycles. For example, prior to the first batch application of Optimized ZIRLO', sufficient L TA data may only be available to confirm the models' applicability up through 45 GWd/MTU. In this example, the licensee would need to confirm the models up through the end of the initial cycle. Subsequently, the licensee would need to confirm the models, based upon the latest L TA data, prior to re~inserting the Optimized ZIRLO' fuel rods in future cycles. Based upon the L TA schedule, it is expected that this issue may only be applicable to the first few batch implementations, since sufficient L TA data up through the burn up limit should be available within a few years.

RESPONSE: Westinghouse has provided the NRC with information related to test data and models in the letters referenced in Section 7 of this enclosure (References 3 - 8).

L TA measured data and favorable results from visual examinations of once, twice, and thrice-burned L TAs confirm, up to the fuel rod burnup limit, that the current fuel performance models are applicable for Optimized ZIRLOTM clad fuel rods. Through transmittal of the information contained in References 3 through 6

8, Westinghouse has fulfilled its obligation to provide additional data from the Optimized ZIRLO' LTA programs to the NRC. NextEra will continue to use the currently approved fuel performance models for all Optimized ZIRLOTM fuel assemblies up to the approved fuel burnup limit.

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 ZIRLO' 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 ZIRLO' fuel rods must be completed prior to their initial batch loading and prior to the startup of subsequent cycles. For example, prior to the first batch application of Optimized ZIRLO', sufficient L TA data may only be available to confirm the models' applicability up through 45 GWd/MTU. In this example, the licensee would need to confirm the models up through the end of the initial cycle. Subsequently, the licensee would need to confirm the models, based upon the latest L TA data~ prior to re-inserting the Optimized ZIRLO' fuel rods in future cycles. Based upon the L TA schedule, it is expected that this issue may only be applicable to the first few batch implementations since sufficient L TA data up through the burnup limit should be available within a few years.

RESPONSE: Westinghouse has provided the NRC with information related to test data and models in References 3 through 8.

The data from three cycles of operation has been evaluated, and the fuel rod creep models from fuel rod design codes have been used to predict the growth and creep performance of the samples. Through transmittal of the information contained in References 3 through 8, Westinghouse has fulfilled its obligation to provide additional data from the Optimized ZIRLO' L TA programs to the NRC.

NextEra will continue to use the currently approved fuel performance models for all Optimized ZIRLO' fuel assemblies up to the approved fuel burnup limit.

8.

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

a.

For the Westinghouse fuel design analyses:

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i.

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

ii.

Between BOL up to a radiation fluence of 3.0 x 1021 n/cm2 (E>1 MeV), pseudo-irradiated Optimized ZIRLO' 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 ZIRLO' and at a fluence of 3.0 x 1021 n/cm2 (E>1 MeV), irradiated strength of standard ZIRLO at the fluence of 3.0 x 1021 n/cm2 (E>1 MeV) minus 3 ksi.

iii.

During subsequent irradiation from 3.0 x 1021 n/cm2 up to 12 x 1021 n/cm2, the differences in strength (the difference at a fluence of 3 x 1 021 n/cm2 due to tin content) shall be decreased linearly such that the pseudo-irradiated Optimized ZIRLO' strengths will saturate at the same properties as standard Zl RLO at 12 x 1021 n/cm2.

b.

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

RESPONSE: Point Beach Units 1 and 2 use a Westinghouse fuel design, and therefore, Condition 8.b does not apply.

The fuel analysis of Optimized ZIRLO' clad rods will use the yield strength and ultimate tensile strength as modified per Conditions 8.a.i, 8.a.ii, and 8.a.iii until such time that irradiated data for Optimized ZIRLO' strengths have been collected and provided to the NRC. Until such time, NextEra will confirm that the requirements of these Conditions are met as applicable to Point Beach Units 1 and 2'as part of the normal reload design process.

9.

As discussed in response to RAI #21, for plants introducing Optimized ZIRLO' that are licensed with LOCBART or STRIKIN-11 and have a limiting PCT that occurs during blowdown or early reflood, the limiting LOCBART or STRIKIN-11 calculation will be rerun using the specified Optimized ZIRLO' material properties. Although not a condition of approval, the NRC staff strongly recommends that, for future evaluations, Westinghouse update all computer models with Optimized ZIRLO' specific material properties.

RESPONSE: Point Beach Units 1 and 2 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 ZIRLO',

the Westinghouse coolability limit on PCT during the locked rotor event shall be

[proprietary limits included in topical report and proprietary version of safety eva I uation].

8

RESPONSE: The PCT calculated by Westinghouse for the locked rotor event has been assessed relative to the Optimized ZIRLO' PCT limit as part of the Point Beach Extended Power Uprate (Reference 15). This will be reassessed as part of the normal reload design process.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria Point Beach Nuclear Plant (PBNP) was licensed prior to the 1971 publication of 10 CFR 50, Appendix A, General Design Criteria (GDC) (ML003674718). As such, PBNP is not licensed to Appendix A GDCs. PBNP Final Safety Analysis Report (FSAR)

Section 1.3 lists the plant-specific GDCs to which the plant was licensed. The PBNP GDCs are similar in content to the draft GDCs proposed for public comment in 1967.

The following discussion addresses the proposed changes with respect to meeting the requirements of the applicable draft design criteria to which PBNP is licensed.

PBNP GDC 44 - Emergency Core Cooling System Capability: An emergency core cooling system with the capability for accomplishing adequate emergency core cooling shall be provided. This core cooling system and the core shall be designed to prevent fuel and clad damage that would interface with the emergency core cooling function and to limit the clad metal-water reaction to acceptable amounts for all sizes of breaks in the reactor coolant piping up to the equivalent of a double-ended rupture of the largest pipe.

The performance of such emergency core cooling system shall be evaluated conservatively in each area of uncertainty.

The NRC's regulatory requirements related to the acceptance criteria for emergency core cooling systems for light-water nuclear power reactors are set forth in 10 CFR 50.46. The criteria are:

(1) Peak cladding temperature. The calculated maximum fuel element cladding temperature shall not exceed 2200° F.

(2) Maximum cladding oxidation. The calculated total oxidation of the cladding shall nowhere exceed 0.17 times the total cladding thickness before oxidation.

(3) Maximum hydrogen generation. The calculated total amount of hydrogen generated from the chemical reaction of the cladding with water or steam shall not exceed 0.01 times the hypothetical amount that would be generated if all of the metal in the cladding cylinders surrounding the fuel, excluding the cladding surrounding the plenum volume, were to react.

(4) Coo/able geometry. Calculated changes in core geometry shall be such that the core remains amenable to cooling.

(5) Long-term cooling. After any calculated successful initial operation of the ECCS, the calculated core temperature shall be maintained at an acceptably low value and decay heat shall be removed for the extended period of time required by the long-lived radioactivity remaining in the core.

In addition, 10 CFR 50 Appendix K (ECCS Evaluation Models) Paragraph I.A.5 requires 9

use of the Baker-Just equation to be used to predict the rates of energy release, hydrogen concentration, and cladding oxidation for the metal-water reaction.

PBNP GDC 44, 10 CFR 50.46 criteria and 10 CFR 50 Appendix K requirements will continue to be met since the plant-specific LOCA analyses using Optimized ZIRLOTM properties demonstrate that the acceptance criteria of 10 CFR 50.46 are satisfied.

The proposed amendment would revise Technical Specification (TS) 4.2.1, "Fuel Assemblies," to add Optimized ZIRLO' to the approved fuel rod cladding material and TS 5.6.4 "Core Operating Limits Report (COLR)," to add Westinghouse Electric Company LLC (Westinghouse) topical report WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO'," to the analytical methods used to determine the core operating limits previously reviewed and approved by the Nuclear Regulatory Commission (NRC).

In accordance with Conditions and Limitations item one of the SE (Reference 2),

NextEra is requesting approval for exemption from 10 CFR 50.46 and 10 CFR Part 50 Appendix K to allow the use of Optimized ZIRLO' fuel rod cladding in future core reload applications for Point Beach Units 1 and 2, pursuant to 10 CFR 50.12. The requested exemption would allow use of a different fuel cladding, Optimized ZIRLO',

as described in Westinghouse topical report WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO'" (Reference 1). The exemption request for the use of Optimized ZIRLO' as the fuel rod cladding, is provided in Attachment 1.

4.2 Precedent The proposed amendment would allow use of new fuel cladding, as described in Westinghouse topical report WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO'." The NRC has approved the Westinghouse topical report (Reference 2).

Furthermore, several licensees have received staff approval to use Optimized ZIRLO '.

Dominion has received approval at North Anna Power Station, Units 1 and 2 (Reference 9), Surry Power Station Units 1 and 2 (References 10 and 11 ), and, most recently, Millstone Power Station Unit 3 (Reference 12). Indiana Michigan Power Company has also received approval at D.C. Cook Nuclear Plant Units 1 and 2 (References 13 and 14) 4.3 List of Commitments Since plant-specific TS changes are required prior to utilizing Optimized ZIRLO' fuel rod cladding, no new commitments are necessary to support NRC approval of this license amendment request.

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4.4 No Significant Hazards Consideration Determination The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazard 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.

The proposed amendment does not involve a significant hazards consideration for the following reasons:

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

Response: No.

The proposed change would allow the use of Optimized ZIRLO' clad nuclear fuel in the reactors. The NRC approved topical report WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A "Optimized ZIRLO'," prepared by Westinghouse Electric Company LLC (Westinahouse), which addresses Optimized ZIRLO' and demonstrates that Optimized ZIRLOT has essentially the same properties as currently licensed ZIRLO. The fuel cladding itself is not an accident initiator and does not affect accident probability. Use of Optimized ZIRLO' fuel cladding will continue to meet all10 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 ZIRLO' clad fuel will not result in changes to the operation or configuration of the facility. Topical Report WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO'" demonstrated that the material properties of Optimized ZIRLO' are similar to those of standard ZIRLO. Therefore, Optimized ZIRLO' fuel rod cladding will perform similarly to the cladding fabricated from standard ZIRLO, thus precluding the possibility of the fuel becoming an accident initiator and causing a new or different type of accident. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any 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 because it has been demonstrated that the material properties of the Optimized 11

ZIRLOTM are not significantly different from those of standard ZIRLO. Optimized ZIRLO' is expected to perform similarly to standard ZIRLO for all normal operating and accident scenarios, including both loss of coolant accident (LOCA) and non-LOCA scenarios. For LOCA scenarios, the slight difference in Optimized ZIRLO' material properties relative to standard ZIRLO could have some impact on the overall accident scenario. However, all acceptance criteria of 10 CFR 50.46 are satisfied, therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, NextEra concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

5.0 Environmental Consideration 10 CFR 51.22(c)(9) provides criteria for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment.

A proposed amendment of an operating license for a facility requires no environmental assessment, if the operation of the facility in accordance with the proposed amendment does not: (1) involve a significant hazards consideration, (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and (3) result in a significant increase in individual or cumulative occupational radiation exposure. NextEra has reviewed this LAR and determined that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment. The basis for this determination follows.

Basis This change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons:

1.

As demonstrated in the 10 CFR 50.92 evaluation, the proposed amendment does not involve a significant hazards consideration.

2.

The proposed change provides a reduced corrosion rate while maintaining the benefits of mechanical strength and resistance to accelerated corrosion from abnormal chemistry conditions. Thus, the proposed amendment will not result in a significant change in the types or increase in the amounts of any effluents that may be released offsite.

3.

The proposed amendment does not result in a significant increase in individual or cumulative occupational radiation exposure. There are no changes to the source term or radiological release assumptions used in evaluating the radiological consequences in the PBNP UFSAR. The proposed changes have no adverse impact on component or system interactions. The proposed changes will not degrade the ability of systems, structures or components important to safety to perform their safety function nor change the response of any system, structure or component important to safety as described in the 12

PBNP UFSAR. The proposed changes do not alter the design assumptions, conditions, or configurations of the facilities or the manner in which the units are operated. Hence, the proposed amendment does not result in a significant increase in individual or cumulative occupational radiation exposure.

6.0 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.

7.0 References

1.

WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO',"

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 ZIRLO," June 10, 2005.

3.