ML14112A072

Proposed License Amendment and Exemption Request for the Use of M5 Fuel Rod Cladding

ML14112A072
Person / Time
Site:	Millstone
Issue date:	04/11/2014
From:	Sartain M D Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
14-053
Download: ML14112A072 (21)

Text

_0 Dominion Nuclear Connecticut, Inc. 1i Dominion 5000 Dominion Boulevard, Glen Allen, VA 23060 Web Address: www.dom.com April 11,2014 U.S. Nuclear Regulatory Commission Serial No.14-053 Attention:

Document Control Desk NLOS/WDC RO Washington, DC 20555 Docket No. 50-336 License No. DPR-65 DOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 2 PROPOSED LICENSE AMENDMENT AND EXEMPTION REQUEST FOR THE USE OF M5 FUEL ROD CLADDING Pursuant to 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) requests an amendment, in the form of changes to the Technical Specifications (TS) to Facility Operating License Number DPR-65 for Millstone Power Station Unit 2 (MPS2). The proposed change will add the Framatome-ANP (AREVA) topical report for the M51 fuel rod cladding material to TS 6.9.1.8.b, "Core Operating Limits Report," which lists the analytical methods used to determine the core operating limits. The M5 fuel rod cladding material was approved by the NRC in Topical Report BAW-10240(P)(A), Revision 0,"Incorporation of M5TM Properties in Framatome-ANP Approved Methods." A discussion of the proposed change is included in Attachment

1. The marked-up TS page is included in Attachment 2.To support the change related to the use of M5 cladding material and pursuant to 10 CFR 50.12, DNC is also requesting an exemption from certain requirements of 10 CFR 50.46,"Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors," and Appendix K to 10 CFR 50.46, " ECCS Evaluation Models," for MPS2. The exemption request relates solely to the specific types of cladding material specified in these regulations for use in light water reactors.

As written, the regulations presume use of either Zircaloy or ZIRLO fuel rod cladding.

The exemption request is required since M5 has a slightly different composition than Zircaloy.

The exemption request is included as Attachment 3.DNC requests approval of the proposed amendment and exemption by April 11, 2015 to support the core design for the MPS2 Cycle 25 core reload in the spring of 2017. Once approved, the amendment will be implemented within 60 days.1 M5 is a registered trademark of Framatome-ANP, Inc. A Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Page 2 of 3 If you have any questions regarding this request, please contact Wanda Craft at (804)273-4687.Sincerely, Mark D. Sartain Vice President

-Nuclear Engineering COMMONWEALTH OF VIRGINIA)COUNTY OF HENRICO )The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mark D. Sartain, who is Vice President

-Nuclear Engineering of Dominion Nuclear Connecticut, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.Acknowledged before me this I It'"dayof AtN.[ 2014.My Commission Expires: "2-of Notary Public I Notary Public Commitment made in this letter: None I Commonwealth of Virginia Reg. # 7520495 I My Commission Expires January 31, 20h Attachments:

1. Discussion of Technical Specification Change 2. Marked-up Technical Specification Page 3. Exemption Request Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Page 3 of 3 cc: U.S. Nuclear Regulatory Commission Region I 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 M. C. Thadani Project Manager -Millstone Power Station U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 08 B1 Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station Director, Radiation Division Department of Energy and Environmental Protection 79 Elm Street Hartford, CT 06106-5127 Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Attachment 1 Attachment 1 Discussion of Technical Specification Change DOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 2 Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Attachment 1, Page 1 of 9 Discussion of Technical Specification Change Table of Contents 1.0 Sum m ary Description

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2 2.0 Detailed Description of Proposed Technical Specification Change ...........

2 3.0 D iscussion

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3 4.0 Technical Evaluation

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3 4.1 Assessment of Methodologies not Discussed in BAW-10240

....... 5 4.2 Assessment of Methodologies not Supported by BAW-10240

....... 6 5.0 Regulatory Evaluation

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6 5.1 Applicable Regulatory Requirements and Criteria ...........................

6 5.2 No Significant Hazards Consideration

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6 5.3 Precedents

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8 5.4 Conclusion

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8 6.0 Environmental Considerations

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8 7.0 References

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9 Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Attachment 1, Page 2 of 9 1.0 Summary Description Pursuant to 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) requests an amendment, in the form of changes to the Technical Specifications (TS), to Facility Operating License Number DPR-65 for Millstone Power Station Unit 2 (MPS2). The proposed change will add the Framatome-ANP (AREVA) topical report for the M51 (hereafter referred as M5) fuel rod cladding material to TS 6.9.1.8.b, "Core Operating Limits Report." The M5 fuel rod cladding material was approved by the NRC in Topical Report BAW-10240(P)(A), Revision 0, "Incorporation of M5TM Properties in Framatome-ANP Approved Methods." The marked-up TS page is included as Attachment 2.To support the change related to the use of M5 cladding material and pursuant to 10 CFR 50.12, DNC is also requesting an exemption from certain requirements of 10 CFR 50.46, "Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors," and Appendix K to 10 CFR 50.46, " ECCS Evaluation Models," for MPS2. The exemption request relates solely to the specific types of cladding material specified in these regulations for use in light water reactors.

As written, the regulations presume use of either Zircaloy or ZIRLO' fuel rod cladding.

The exemption request is required since M5 cladding has a slightly different composition than either of these alloys. The exemption request is included as Attachment 3.DNC currently plans to use fuel assemblies containing M5 fuel rod cladding beginning with the fresh fuel for MPS2 Cycle 25 in the spring of 2017.2.0 Detailed Description of Proposed Technical Specification Change TS 6.9.1.8.b, "Core Operating Limits Report," currently includes 16 documents that define the methods used to determine the core operating limits for MPS2. The proposed revision to this list of references would add AREVA topical report BAW-10240(P)(A) to TS 6.9.1.8.b as Reference

17. The proposed addition is as follows: 17) BAW-10240(P)(A)

Revision 0, "Incorporation of M5TM Properties in Framatome ANP Approved Methods," May 2004.The marked-up TS page showing this change is included in Attachment 2.It should be noted that typographical errors were identified in the document number and/or title of References 5, 7, and 14 in TS 6.9.1.8.b.

These errors will be corrected as part of an administrative TS change request that is currently under development by DNC. These typographical errors are as follows: " Reference 5: In the document number, "EFN" is changed to "EMF"* Reference 7: In the document number, "XN-NF-44' is changed to XN-NF-78-44"" Reference 7: In the title, the words "Rod", "Water" and "Reactor' are capitalized" Reference 14: In the document number, "2130" is changed to "2310" 1 M5 is a registered trademark of Framatome-ANP, Inc.

Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Attachment 1, Page 3 of 9 3.0 Discussion As the nuclear industry has pursued longer operating cycles with increased fuel discharge burnup and fuel duty, the performance requirements for the nuclear fuel cladding have become more demanding.

M5 is an advanced fuel rod cladding composed of primarily zirconium (approximately 99%) and niobium (approximately 1%).It provides significant improvements in corrosion resistance, hydrogen pickup, axial growth, and diametral creep relative to Zircaloy.Framatome-ANP (AREVA) topical reports BAW-10240(P)(A), Revision 0 (Reference 1)and BAW-10227(P)(A), Revision 1, "Evaluation of Advanced Cladding and Structural Material (M5) in PWR Reactor Fuel" (Reference

2) provide the details and results of testing of the M5 cladding material compared to Zircaloy, as well as the material properties to be used in various models and methodologies when analyzing M5 cladding.The NRC has approved the use of M5 fuel cladding based upon the following:

1. Similarities to Zircaloy, and 2. Demonstrated material performance as documented in References 1 and 2 and in the AREVA responses to NRC requests for additional information.

The NRC safety evaluation for topical report BAW-1 0240(P)(A) identified four conditions that are applicable to the use of M5 cladding.

Compliance with these conditions is discussed in Section 4.0 below.The NRC has approved use of M5 fuel rod cladding material for the Calvert Cliffs Nuclear Power Plant, LLC, Units 1 and 2 (ML103270546) and Shearon Harris Nuclear Power Plant, Unit 1 (ML12058A1 33).DNC currently plans to use M5 cladding as the fuel rod cladding material for MPS2 reloads beginning with the new fuel introduced for Cycle 25 in the spring of 2017.4.0 Technical Evaluation The use of the M5 fuel rod cladding material in PWR reactors was approved by the NRC in topical report BAW-10227(P)(A), Revision 1 (Reference 2). The use of M5 cladding for AREVA approved methods was approved in topical report BAW-10240(P)(A)

Revision 0 (Reference 1). The M5 cladding is an AREVA proprietary material composed primarily of zirconium (approximately 99%) and niobium (approximately 1%). This composition has demonstrated superior corrosion resistance and reduced irradiation induced growth relative to both standard and low-tin Zircaloy.The resulting alloy microstructure is highly stable under irradiation and provides improved in-reactor thermal and mechanical performance.

The NRC Safety Evaluation (SE) of BAW-10240(P)(A) approved this topical report for use in license applications for Westinghouse and Combustion Engineering designed Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Attachment 1, Page 4 of 9 pressurized water reactors (PWRs) to the extent specified and under the limitations provided in the topical report and SE. The conditions in the SE for the use of M5 cladding in AREVA's approved methods are as follows: "1. The corrosion limit, as predicted by the best-estimate model will remain below 100 microns for all locations of the fuel." Response:

The restriction that the corrosion limit, as predicted by the best-estimate model, will remain below 100 microns for all locations of the fuel is implemented in the AREVA fuel design processes.

This limit is verified for each reload as part of cycle-specific reload analysis."2. All of the conditions listed in the NRC SEs for all AREVA methodologies used for M5e fuel analysis will continue to be met, except that the use of M5e cladding in addition to Zircaloy-4 cladding is now approved." Response:

Conditions from approved SEs are incorporated as restrictions in AREVA design procedures and guidelines that control the core reload designs for MPS2. This is verified for each reload as part of cycle-specific reload analysis."3. All AREVA methodologies will be used only within the range for which M5e data was acceptable and for which the verifications discussed in BAW-10240(P)-A or BAW-10227(P)-A (Reference

2) were performed." Response:

Limitations to ensure AREVA methodologies will be used only within the range for which M5 data was acceptable, and for which the verifications discussed in BAW-10240(P)(A) or BAW-10227(P)(A) were performed, are incorporated as restrictions in AREVA design procedures and guidelines that control the core reload designs for MPS2. This is verified for each reload as part of cycle-specific reload analysis."4. The burnup limit for implementation of M5e is 62 GWd/MTU." Response:

The burnup limit is unchanged.

This limit, identified in approved methodologies, is contained in MPS2 core functional requirements and AREVA design processes, and is currently limited to 62 GWd/MTU. The limit is verified for each reload as part of cycle specific reload analysis.Therefore, the implementation of the proposed change for MPS2 will remain in compliance with requirements identified in the SE associated with the topical report.

Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Attachment 1, Page 5 of 9 4.1 Assessment of Methodologies not Discussed in BAW-10240(P)(A)

The following methodologies, included in MPS2 TS 6.9.1.8.b, are not specifically discussed in BAW-10240(P)(A): " ANF-84-73 Appendix B (P)(A), "Advanced Nuclear Fuels Methodology for Pressurized Water Reactors:

Analysis of Chapter 15 Events," Advanced Nuclear Fuels Corporation., XN-NF-621(P)(A), "Exxon Nuclear DNB Correlation for PWR Fuel Designs," Exxon Nuclear Company." ANF-89-151(P)(A), "ANF-RELAP Methodology for Pressurized Water Reactors: Analysis of Non-LOCA Chapter 15 Events," Advanced Nuclear Fuels Corporation.

The disposition of each is as follows: ANF-84-73 Appendix B (P)(A) and ANF-89-151(P)(A)

ANF-84-73 Appendix B (P)(A) (Reference

3) and ANF-89-151(P)(A) (Reference 4)detail non-loss of coolant accident (LOCA) methods for the analysis of FSAR Chapter 14 Safety Analysis events based on the application of the PTSPWR and the ANF-RELAP computer codes, respectively.

BAW-10240(P)(A) evaluates the impact of M5 cladding on non-LOCA events by assessing the impact on EMF-2310(P)(A) (Reference 5). EMF-2310(P)(A), an NRC-approved PWR non-LOCA transient analysis methodology incorporating S-RELAP5 as the systems analysis code in place of ANF-RELAP and PTSPWR, is applicable to PWR non-LOCA events.BAW-10240(P)(A) assesses the impact of M5 cladding on non-LOCA events as negligible and concludes that EMF-2310(P)(A) does not require revision to address the use of M5 cladding.

Since ANF-84-73 Appendix B (P)(A) and ANF-89-151(P)(A) are based on similar methodologies and model the same events as EMF-2310(P)(A), it is concluded that the use of M5 cladding also has a negligible impact on the application of ANF-84-73 Appendix B (P)(A) and ANF-89-151(P)(A) methodologies to the design of M5 cladding reloads.XN-NF-621 (P)(A)XN-NF-621(P)(A) (Reference

6) describes a departure from nucleate boiling (DNB)correlation that is used in the Chapter 14 Safety Analysis.

BAW-10240(P)(A) evaluates the impact of M5 cladding on the high thermal performance (HTP) DNB correlation documented in EMF-92-153(P)(A).

BAW-10240(P)(A) assessed the use of the M5 cladding as having no impact on EMF-92-153(P)(A).

Since XN-NF-621(P)(A) also documents a DNB correlation which supports the analysis of FSAR Chapter 14 Safety Analysis events, it is concluded that the use of M5 cladding has no impact on XN-NF-621 (P)(A).

Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Attachment 1, Page 6 of 9 4.2 Assessment of Methodology not Supported by BAW-10240(P)(A)

BAW-10240(P)(A) does not support the use of the large break LOCA (LBLOCA)analysis methodology of EMF-2087(P)(A) with the M5 fuel rod cladding.

EMF-2087(P)(A) is currently listed in the MPS2 list of approved COLR methodologies.

As discussed in a pre-submittal meeting on July 17, 2013 between Dominion and the NRC (Reference 7), a future submittal is planned to replace the LBLOCA methodology of EMF-2087(P)(A) with a LBLOCA methodology that is acceptable for use with the M5 fuel rod cladding material.5.0 Regulatory Evaluation 5.1 Applicable Regulatory Requirements and Criteria The NRC approved use of the M5 fuel rod cladding material in AREVA fueled reactors provided licensees ensure compliance with the conditions set forth in the NRC SE for topical report BAW-10240(P)(A).

The use of the M5 fuel rod cladding material in PWR reactors was approved by the NRC in topical report BAW-10227(P)(A), Revision 1 and its use in AREVA-approved methods was approved in topical report BAW-10240(P)(A)

Revision 0. Each of the four conditions were specifically addressed for their applicability to MPS2 in Section 4.0, Technical Evaluation, of this submittal.

In summary: " The limits, conditions, and requirements related to the four conditions are verified for each reload as part of cycle-specific reload analysis.* The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met. An exemption request from the requirement of 10 CFR 50.46, "Acceptance Criteria for Emergency Core Cooling Systems for Light-Water Nuclear Power Reactors," and 10 CFR Part 50, Appendix K, "ECCS Evaluation Models," for use of M5 cladding is required.

The exemption request is provided in Attachment 3 of this letter. The proposed change does not require relief from any other regulatory requirements and does not affect conformance with a General Design Criterion differently than described in the MPS2 Final Safety Analysis Report (FSAR).5.2 No Significant Hazards Consideration DNC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92,"Issuance of Amendment," as discussed below: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Attachment 1, Page 7 of 9 Response:

No.The proposed TS change is: 1) adding BAW-10240(P)(A) to the list of approved methodologies for determining core operating limits at MPS2.The proposed change to TS 6.9.1.8.b permits the use of the appropriate methodology to analyze accidents for cores containing fuel with M5 cladding to ensure that the plant continues to meet applicable design criteria and safety analysis acceptance criteria.

The proposed change to the list of NRC-approved methodologies listed in TS 6.9.1.8.b has no impact on plant operation and configuration.

The list of methodologies in TS 6.9.1.8.b does not impact either the initiation of an accident or the mitigation of its consequences.

The NRC has previously approved use of M5 fuel rod cladding material provided that licensees ensure compliance with the conditions set forth in the NRC SE for topical report BAW-10240(P)(A).

Confirmation that these conditions are satisfied is performed under 10 CFR 50.59 as part of the normal core reload process.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 addition of topical report BAW-10240(P)(A) to the list of NRC approved methodologies listed in TS 6.9.1.8.b, has no impact on any plant configuration or system performance.

There is no change to the parameters within which the plant is normally operated, and thus, the possibility of a new or different type of accident is not created.Therefore, the addition of BAW-10240(P)(A) to TS 6.9.1.8.b does not create the possibility of a new or different kind of accident or malfunction from those previously evaluated within the FSAR.3. Does the proposed change involve a significant reduction in a margin of safety?Response:

No.The proposed change to the list of NRC-approved methodologies listed in TS 6.9.1.8.b has no impact on any plant configuration or system performance.

Topical report BAW-10240(P)(A) has been reviewed and approved by the NRC for use with M5 fuel rod cladding.

Approved methodologies will be used to ensure that the plant continues to meet applicable design criteria and safety Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Attachment 1, Page 8 of 9 analysis acceptance criteria.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.Based on the above information, DNC concludes that the proposed license amendment presents no significant hazards consideration under the criteria set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

5.3 Precedents The proposed change to the MPS2 TSs is similar to the following proposed changes to allow use of fuel with M5 fuel cladding:* Calvert Cliffs Nuclear Power Plant LLC, Units 1 and 2 (ML093350099), dated November 23, 2009.* Shearon Harris Nuclear Power Plant, Unit 1 (ML110250265), dated January 13, 2011.The NRC approved use of M5 fuel rod cladding material in reload quantities for the Calvert Cliffs Nuclear Power Plant, LLC, Units 1 and 2 (ML103270546) and Shearon Harris Nuclear Power Plant, Unit 1 (ML12058A133).

5.4 Conclusion Based on the considerations discussed above, there is reasonable assurance that (1)the health and safety of the public will not be endangered by the operation of MPS2 with M5 fuel rod cladding, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the requested license amendment will not be inimical to the common defense and security or to the health and safety of the public.6.0 Environmental Considerations DNC has reviewed the proposed license amendment for environmental considerations.

The proposed license 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 from an environmental assessment as set forth in 10 CFR 51.22(c)(9).

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

Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Attachment 1, Page 9 of 9 7.0 References

1. BAW-10240(P)(A), Revision 0, "Incorporation of M5TM Properties in Framatome ANP Approved Methods," May 2004.2. BAW-10227(P)(A), Revision 1, "Evaluation of Advanced Cladding and Structural Material (M5) in PWR Reactor Fuel," June 2003.3. ANF-84-73 Appendix B (P)(A), "Advanced Nuclear Fuels Methodology for Pressurized Water Reactors:

Analysis of Chapter 15 Events," Advanced Nuclear Fuels.4. ANF-89-151(P)(A), "ANF-RELAP Methodology for Pressurized Water Reactors: Analysis of Non-LOCA Chapter 15 Events," Advanced Nuclear Fuels Corporation.

5. EMF-2310(P)(A)

Revision 0, "SRP Chapter 15 Non-LOCA Methodology for Pressurized Water Reactors," Framatome ANP, May 2001.6. XN-NF-621(P)(A), "Exxon Nuclear DNB Correlation for PWR Fuel Designs," Exxon Nuclear Company.7. James Kim (USNRC) letter to Dominion Nuclear Connecticut, Inc., "Summary of July 17, 2013, Meeting with Dominion Nuclear Connecticut, Inc. and AREVA to discuss Upgrade to AREVA Standard CE14 HTP Fuel Assembly," dated July 30, 2013 (ML13207A259).

Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Attachment 2 Marked-up Technical Specification Page DOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 2 Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Attachment 2, Page 1 of 1 ADMINISTRATIVE CONTROLS CORE OPERAT'ING LIMITS REPORT (CONT.)8) XN-NF-621(P)(A), "Exxon Nuclear DNB Correlation for PWR Fuel Designs," Exxon Nuclear Company.9) XN-NF-82-06(P)(A), and Supplements 2, 4 and 5, "Qualification of Exxon.Nuclear Fuel for Extended Burnup," Exxon Nuclear Company.10) ANF-88-133(P)(A)and Supplement 1, "Qualification of Advanced Nuclear Fuels PWR Design Methodology for Rod Burnups of 62 GWd/MTU," Advanced Nuclear Fuels Corporation.

11) XN-NF-85-92(P)(A), "Exxon Nuclear Uranium Dioxide/Gadolinia Irradiation Examination and Thermal Conductivity Results," Exxon Nuclear Company.12) ANF-89-151(P)(A), "ANF-RELAP Methodology for Pressurized Water Reactors:

Analysis of Non-LOCA Chapter 15 Events," Advanced Nuclear Fuels Corporation.

13) EMF-1961 (P)(A), "Statistical Setpoint/Transient Methodology for Combustion Engineering Type Reactors," Siemens Power Corporation.

14) EMF-2130(P)(A), "SRP Chapter 1:5 Non-LOCA Methodology for Pressurized Water Reactors," Framatome ANP.15) EMF-92-153(P)(A) and Supplement 1, "HTP: Departure from Nucleate Boiling Correlation for High 'Ilermal Performance Fuel," Siemens Power Corporation.

16) EMF-92-116(P)(A)

Revision 0, "Generic Mechanical Design Criteria.for L PWR Fuel Designs," Siemens Power Corporation.

1 c. The core operating limits shall be determined so that all applicable limits (e.g., fuel.thermal-mechanical limits, core thermal-hydraulic limits, ECCS limits, nuclear limits such as SHUTDOWN MARGIN, and transient and accident analysis limits)of the safety analysis are met.d. The CORE OPERATING LIMITS REPORT, including any mid-cycle revisions or S supplements thereto, shall be provided upon issuance, for each reload cycle, to the NRC Document Control Desk with copies to the Regional Administrator and Resident Inspector.

17) BAW-10240(P)(A)

Revision 0, "Incorporation of M5TM Properties in Framatome ANP Approved Methods," May 2004.MILLSTONE

-UNIT 2 6-19 Amendment No. 448, 416-3, 2-2, -099-5.

Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Attachment 3 Exemption Request DOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 2 Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Attachment 3, Page 1 of 5 Request for Exemption from the Provisions of 10 CFR 50.46 and 10 CFR Part 50 Appendix K to Allow Use of M5 Fuel Rod Cladding in Core Reload Applications Table of Contents 1.0 Purpose .............................................................................................

2 2.0 Background

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2 3.0 Technical Justification of Acceptability

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2 4.0 Justification of Exemption

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3 5.0 Special Circumstances Support the Issuance of an Exemption

....... 4 6.0 Conclusion

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5 7.0 References

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5 Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Attachment 3, Page 2 of 5 1.0 Purpose In accordance with the specific requirements of 10 CFR 50.12, "Specific Exemptions," Dominion Nuclear Connecticut, Inc. (DNC) 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 M51 (hereafter referred to as M5) fuel rod cladding in future core reload applications for Millstone Power Station Unit 2 (MPS2). The regulation in 10 CFR 50.46 contains acceptance criteria for the emergency core cooling system (ECCS) for reactors that have fuel rods fabricated either with Zircaloy or ZIRLO cladding.

Appendix K to 10 CFR Part 50, paragraph I.A.5, requires the Baker-Just equation to be used to predict the rates of energy release, hydrogen generation, and cladding oxidation for the metal-water reaction.

The Baker-Just equation assumed the use of a zirconium alloy different than M5 material.

Therefore, an exemption to 10 CFR 50.46 and 10 CFR Part 50, Appendix K is required to support the use of M5 fuel rod cladding.

The exemption request relates solely to the specific cladding material specified in these regulations (i.e., fuel rods with Zircaloy or ZIRLOcladding).

This request provides for application of the acceptance criteria of 10 CFR 50.46 and Appendix K to 10 CFR Part 50 to fuel assembly designs using M5 fuel rod cladding.2.0 Background As the nuclear industry pursues longer operating cycles with increased fuel discharge burnup and fuel duty, the performance requirements for the nuclear fuel cladding become more demanding.

M5 cladding is an advanced fuel rod cladding composed of primarily zirconium (approximately 99%) and niobium (approximately 1%). It provides significant improvements in corrosion resistance, hydrogen pickup, axial growth, and diametral creep relative to Zircaloy.Beginning in the spring of 2017, the reloads for MPS2 will contain fuel rods with M5 cladding.

A technical specifications (TS) change for MPS2 is required to allow the use of M5 fuel rod cladding for core reload applications.

The request for this change is provided in Attachment 1 of this submittal.

3.0 Technical Justification of Acceptability Framatome-ANP (AREVA) topical reports BAW-10240(P)(A)

Revision 0,"Incorporation of M5TM Properties in Framatome ANP Approved Methods" (Reference

1) and BAW-10227(P)(A)

Revision 1, "Evaluation of Advanced Cladding and Structural Material (M5) in PWR Reactor Fuel" (Reference

2) provide the details and 1 M5 is a registered trademark of Framatome-ANP, Inc.

Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Attachment 3, Page 3 of 5 results of testing of the M5 material compared to Zircaloy, as well as the material properties to be used in various models and methodologies when analyzing M5 cladding.

The NRC Safety Evaluation (SE) for BAW-10240(P)(A) contains four conditions.

Each of the four conditions are addressed in the technical evaluation for the TS change (see Attachment 1 of this submittal) and will be addressed in evaluations required to support core reload activities.

Since a plant-specific TS change is required prior to using M5 fuel rod cladding, no new commitments are necessary to support NRC approval of this exemption request.The normal core reload evaluations under 10 CFR 50.59 requirements will ensure that acceptance criteria are met for the insertion of assemblies with fuel rods clad with M5 material.

These assemblies will be evaluated using NRC approved methods and models to address the use of M5 fuel rod cladding.4.0 Justification of Exemption 10 CFR 50.12, "Specific Exemptions," states that the NRC may grant exemptions from the requirements of the regulations of this part of the Code of Federal Regulations provided three conditions are met. The three conditions are: 1) the exemption is authorized by law; 2) the exemption will not present an undue risk to the health and safety of the public; and 3) the exemption is consistent with the common defense and security.The requested exemption to allow the use of M5 fuel rod cladding material in addition to Zircaloy material for core reload applications at MPS2 satisfies these criteria as described below.1. This exemption is authorized by law.As required by 10 CFR 50.12 (a)(1), this requested exemption is "authorized by law." The selection of a specified cladding material in 10 CFR 50.46 and implied in 10 CFR Part 50, Appendix K, was adopted at the discretion of the Commission consistent with its statutory authority.

No statute required the NRC to adopt this specification.

Additionally, the NRC has the authority under 10 CFR 50.12 to grant exemptions from the requirements of 10 CFR Part 50 with proper justification.

Furthermore, by submitting this exemption request, MPS2 does not seek an exemption from the acceptance and analytical criteria of 10 CFR 50.46 and 10 CFR Part 50, Appendix K. Rather, the intent of the request is solely to allow the use of criteria set forth in these regulations for application to the M5 fuel rod cladding material.2. This exemption will not present an undue risk to public health and safety.

k.Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Attachment 3, Page 4 of 5 The reload evaluations will ensure that acceptance criteria are met for the insertion of assemblies with fuel rods clad with M5 material.

Fuel assemblies using M5 fuel rod cladding will be evaluated using NRC approved analytical methods and plant-specific models to address the changes in the cladding material properties.

The safety analysis for MPS2 is supported by the applicable site-specific TSs. Reload cores are required to be operated in accordance with the operating limits specified in the TSs. Thus, the granting of this exemption request will not pose an undue risk to public health and safety.3. This exemption is consistent with common defense and security.As noted above, the exemption request is only to allow the application of the regulations to an improved fuel rod cladding material.

The requirements and acceptance criteria will be maintained.

The special nuclear material in these assemblies is required to be handled and controlled in accordance with approved procedures.

Use of full regions of M5 fuel rod cladding in the MPS2 core will not affect plant operations and is consistent with common defense and security.5.0 Special Circumstances Support the Issuance of an Exemption 10 CFR 50.12(a)(2) states that the NRC will not consider granting an exemption to the regulations unless special circumstances are present. The requested exemption meets the special circumstances of 10 CFR 50.12(a)(2)(ii) which states that,"Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule." In this particular circumstance, application of the subject regulations is not necessary to achieve the underlying purpose of the rule.This exemption request relates solely to the specific cladding material specified in 10 CFR 50.46 (i.e., fuel rods with Zircaloy or ZIRLO cladding).

The remaining requirements specified by 10 CFR 50.46 will continue to be applied to MPS2. An evaluation of the MPS2 core will be performed using NRC approved Loss of Coolant Accident (LOCA) methods to ensure that assemblies with M5 fuel rod cladding material meet the LOCA safety criteria.The intent of 10 CFR Part 50, Appendix K, paragraph I.A.5 is to apply an equation for rates of energy release, hydrogen generation, and cladding oxidation from a metal-water reaction that conservatively bounds the post-LOCA scenarios (i.e., the Baker-Just equation).

In Appendix D of Reference 2, application of the Baker-Just equation has been demonstrated to be appropriate for the M5 alloy. Due to the similarities in the composition of the M5 and Zircaloy fuel rod cladding materials, the application of the Baker-Just equation will continue to conservatively bound the post-LOCA scenarios.

Serial No.14-053 Docket No. 50-336 Proposed LAR -M5 Fuel Rod Cladding Attachment 3, Page 5 of 5 6.0 Conclusion The acceptance criteria and requirements of 10 CFR 50.46 and 10 CFR Part 50, Appendix K currently are limited in applicability to the use of fuel rods with Zircaloy or ZIRLO cladding.

10 CFR 50.46 and 10 CFR Part 50, Appendix K do not apply to the proposed use of M5 fuel rod cladding material since M5 cladding has a slightly different composition than either of the currently specified alloys. With the approval of this exemption request, these regulations will be applied to M5 fuel rod cladding, so that M5 cladding may be used at MPS2.In order to support the use of M5 fuel rod cladding material, an exemption from the requirements of 10 CFR 50.46 and 10 CFR Part 50, Appendix K is requested.

As required by 10 CFR 50.12, the requested exemption is authorized by law, does not present undue risk to public health and safety, and is consistent with common defense and security.

Approval of this exemption request does not violate the underlying purpose of the rule. In addition, special circumstances do exist to justify the approval of an exemption from the subject requirements.

7.0 References

1. BAW-10240(P)(A), Revision 0, "Incorporation of M5TM Properties in Framatome ANP Approved Methods," May 2004.2. BAW-10227(P)(A), Revision 1, "Evaluation of Advanced Cladding and Structural Material (M5) in PWR Reactor Fuel," June 2003.