ML13183A056

License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Optimized Zirlo Fuel Rod Cladding

ML13183A056
Person / Time
Site:	Seabrook
Issue date:	06/25/2013
From:	Walsh K NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
SBK-L-13070
Download: ML13183A056 (26)

Text

NEXTera SBK-L-13070 10 CFR 50.90 10 CFR 50.12 Docket No. 50-443 June 25, 2013 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, D.C. 20555-0001 Seabrook Station License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Optimized ZIRLO Fuel Rod Cladding In accordance with the provisions of 10 CFR 50.90, NextEra Energy Seabrook, LLC (NextEra)is submitting License Amendment Request (LAR) 13-04 to revise the Seabrook Station Technical Specifications (TS) to allow the use of Optimized ZIRLOTM as an approved fuel rod cladding.

This change is consistent with the U.S. Nuclear Regulatory Commission (NRC)allowed use of Optimized ZIRLOTM fuel cladding material as documented in the Safety Evaluation included in Addendum 1-A to Westinghouse topical report WCAP- 12610-P-A

&CENPD-404-P-A, "Optimized ZIRLOTM.

To support this change to allow the use of Optimized ZIRLOTM in accordance with 10 CFR 50.12, NextEra 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, "ECCS Evaluation Models." This 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 is required since Optimized ZIRLOTM has slightly different composition than Zircaloy or standard ZIRLO.The Enclosure to this letter provides NextEra's evaluation of the proposed changes, and Attachment 1 to the enclosure provides the exemption request. NextEra evaluated the proposed changes in accordance with the criteria provided in 10 CFR 50.12(a) and determined that the request satisfies the requirements for an exemption from certain requirements of 10 CFR 50.46 and Appendix K to 10 CFR Part 50 for Seabrook Station. Attachment 2 to the enclosure provides markups of the TS that show the proposed changes. As discussed in the evaluation, the proposed changes do not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with the change.NextEra Energy Seabrook, LLC.626 Lafayette Rd, Seabrook, NH 03874 Seabrook Nuclear Power Plant SBK-L- 13070 Docket No. 50-443 Page 2 of 2 The Station Operation Review Committee has reviewed this LAR. A copy of this LAR has been forwarded to the New Hampshire State Liaison Officer pursuant to 10 CFR 50.91 (b).This letter contains no new Regulatory Commitments and no revision to existing Regulatory Commitments.

NextEra requests NRC review and approval of LAR 13-04 and the related exemption request by July 1, 2014, and implementation within 60 days.If you have any questions or require additional information, please contact Mr. Michael O'Keefe, Licensing Manager, at (603) 773-7745.I declare under penalty of perjury that the foregoing is true and correct.Executed on JuneX_, 2013.Sincerely,;

Kevi alsh Site Vice President NextEra Energy Seabrook, LLC Enclosure cc: USNRC Regional Administrator, Region I J. G. Lamb, USNRC Project Manager, Project Directorate 1-2 USNRC Senior Resident Inspector, Seabrook Nuclear Plant Director, Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399 Seabrook Nuclear Plant Docket No. 50-443 License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Ontimized ZIRLO Fuel Rod Cladding SBK-L-13070 Enclosure Page 1 of 14 Seabrook Unit I LICENSE AMENDMENT REQUEST 13-04 & EXEMPTION REQUEST -OPTIMIZED ZIRLO T M FUEL ROD CLADDING Enclosure 24 pages Seabrook Nuclear Plant SBK-L-13070 Docket No. 50-443 Enclosure License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Page 2 of 14 Optimized ZIRLO Fuel Rod Cladding TABLE OF CONTENTS LICENSE AMENDMENT REQUEST 13-04 & EXEMPTION REQUEST -OPTIMIZED ZIRLOTM FUEL ROD CLADDING SECTION TITLE PAGE--- Cover Sheet I--- Table of Contents 2 1.0 Summary Description 3 2.0 Detailed Description 4 3.0 Technical Evaluation 5 4.0 Regulatory Evaluation 10 4.1 Applicable Regulatory Requirements/Criteria

4.2 Precedent

4.3 No Significant Hazards Determination

4.4 Conclusions

5.0 Environmental Consideration 13 6.0 References 13 ATTACHMENT TOTAL PAGES 1 Request for Exemption from the Provisions of 10 CFR 6 50.46 & 10 CFR Part 50 Appendix K to Allow Use of Optimized ZIRLO T M Fuel Cladding 2 Technical Specification Markups 4 Seabrook Nuclear Plant SBK-L-13070 Docket No. 50-443 Enclosure License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Page 3 of 14 Optimized ZIRLO Fuel Rod Cladding 1.0

SUMMARY

DESCRIPTION NextEra Energy Seabrook, LLC (NextEra) proposes to revise the Seabrook Station Technical Specifications (TS) to allow the use of Optimized ZIRLOTM fuel rod cladding material.

The current acceptable fuel rod cladding material is identified in TS 5.3.1, Reactor Core, Fuel Assemblies.

The proposed change would revise TS 5.3.1 to add Optimized ZIRLOTM to the approved fuel rod cladding materials and TS 6.8.1.6.b to add Westinghouse Electric Company LLC (Westinghouse) topical report WCAP-12610-P-A

& CENPD-404-P-A, Addendum 1-A "Optimized ZIRLOTM,

to the analytical methods used to determine the core operating limits previously reviewed and approved by the Nuclear Regulatory Commission (NRC).Additionally, 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 ZIRLOTM fuel rod cladding in future core reload applications for Seabrook.

This exemption request is included as Attachment 1.Optimized ZIRLOTM was developed to meet the needs of longer operating cycles with increased fuel discharge burnup and fuel duty. Optimized ZIRLOT fuel cladding is different from standard ZIRLOTM 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 ZIRLOTM 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) has 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.

Seabrook Nuclear Plant SBK-L- 13070 Docket No. 50-443 Enclosure License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Page 4 of 14 Optimized ZIRLO Fuel Rod Cladding 2.0 DETAILED DESCRIPTION A specific description of each change is provided below. In addition, TS mark-ups are provided in Attachment 2 of this document.2.1 Technical Specification 5.3.1, Reactor Core, Fuel Assemblies Current TS The reactor shall contain 193 fuel assemblies.

Each assembly shall consist of a matrix of cylindrical ZIRLO or Zircaloy-4 clad fuel rods with an initial composition of natural or slightly enriched uranium dioxide (U0 2)as fuel material.

Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with NRC-approved applications of fuel rod configurations, may be used. Fuel assemblies shall be limited to those designs that have been analyzed with applicable NRC staff-approved codes and methods and shown by tests or analyses to comply with all fuel safety design bases. A limited number of lead test assemblies that have not completed representative testing may be placed in nonlimiting core regions. Reload fuel shall be similar in physical design to the initial core loading and shall have a maximum enrichment of 5.0 weight percent U-235.Proposed TS The reactor shall contain 193 fuel assemblies.

Each assembly shall consist of a matrix of cylindrical Zircaloy-4, ZIRLO, or Optimized ZIRLO T M clad fuel rods with an initial composition of natural or slightly enriched uranium dioxide (U0 2) as fuel material.

Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with NRC-approved applications of fuel rod configurations, may be used.Fuel assemblies shall be limited to those designs that have been analyzed with applicable NRC staff-approved codes and methods and shown by tests or analyses to comply with all fuel safety design bases. A limited number of lead test assemblies that have not completed representative testing may be placed in nonlimiting core regions. Reload fuel shall be similar in physical design to the initial core loading and shall have a maximum enrichment of 5.0 weight percent U-235.

Seabrook Nuclear Plant SBK-L- 13070 Docket No. 50-443 Enclosure License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Page 5 of 14 Optimized ZIRLO Fuel Rod Cladding 2.2 Technical Specification 6.8.1.6, Core Operating Limits Report Current TS The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC in: 13. WCAP- 12610-P-A, "VANTAGE + Fuel Assembly Reference Core Report". April, 1995, (Westinghouse Proprietary).

Methodology for Specification:

3.2.2 -Heat Flux Hot Channel Factor Proposed TS The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC in: 13. WCAP- 12610-P-A, "VANTAGE + Fuel Assembly Reference Core Report". April, 1995, (Westinghouse Proprietary).

WCAP-12610-P-A

& CENPD-404-P-A, Addendum 1-A,"Optimized ZIRLO T M", July 2006.Methodology for Specification:

3.2.2 -Heat Flux Hot Channel Factor 3.0 TECHNICAL EVALUATION Optimized ZIRLOTM is described in Westinghouse topical report WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A "Optimized ZIRLOTM

[Reference 1].The NRC staff s Safety Evaluation (SE) for Optimized ZIRLOTM [Reference 2]requires that licensees referencing Addendum 1-A to implement Optimized ZIRLOM comply with the ten conditions and limitations listed within the SE.The ten conditions and limitations laid out in the NRC's SE 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 Optimized ZIRLOTM has been completed, implementation of Optimized ZIRLOTM fuel clad requires an exemption from 10 CFR 50.46 and 10 CFR Part 50 Appendix K.

Seabrook Nuclear Plant SBK-L-13070 Docket No. 5 0-443 Enclosure License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Page 6 of 14 Optimized ZIRLO Fuel Rod Cladding RESPONSE:

A request for the required exemption from 10 CFR 50.46 and 10 CFR Part 50 Appendix K is provided as a separate attachment to this submittal.

2. The fuel rod burnup limit for this approval remains at currently established limits: 62 GWd/MTU for Westinghouse fuel designs and 60 GWd/MTU for CE fuel designs.RESPONSE:

For any fuel using Optimized ZIRLOTM fuel rod cladding, the maximum fuel rod burnup limit for Westinghouse fuel designs will continue to be 62 GWd/MTU until such time that a new fuel rod burnup limit is approved for use.3. The maximum fuel rod waterside corrosion, as predicted by the best-estimate model, will [satisfy proprietary limits included in topical report and proprietary version of safety evaluation]

of hydrides for all locations of the fuel rod.RESPONSE:

The maximum fuel rod waterside corrosion for fuel using Optimized ZIRLOTM fuel rod cladding will be confirmed to be less than the specified proprietary limits for all locations of the fuel rod.Evaluations are performed to confirm that the appropriate corrosion limits are satisfied as part of the normal reload design process.4. All the conditions listed in previous NRC SE approvals for methodologies used for standard ZIRLO and Zircaloy-4 fuel analysis will continue to be met, except that the use of Optimized ZIRLOTM cladding in addition to standard ZIRLO and Zircaloy-4 cladding is now approved.RESPONSE:

The fuel analysis of Optimized ZIRLOTM fuel rod cladding will continue to meet all conditions associated with approved methods.For Seabrook, this is a current requirement, and confirmation of these conditions is required as part of the normal reload design process.5. All methodologies will be used only within the range for which ZIRLOand Optimized ZIRLOTM 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 ZIRLOTM,,'

July 2006. For Seabrook, this is a current Seabrook Nuclear Plant SBK-L-13070 Docket No. 50-443 Enclosure License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Page 7 of 14 Optimized ZIRLO Fuel Rod Cladding requirement, and confirmation of these conditions is required as part of the normal reload design process.6. The licensee is required to ensure that Westinghouse has fulfilled the following commitment:

Westinghouse shall provide the NRC staff with a letter(s) containing the following information (Based on the schedule described in response to RAI #3): a. Optimized ZIRLOTM LTA (Lead Test Assembly) data from Byron, Calvert Cliffs, Catawba, and Millstone.

i. Visual ii. Oxidation of fuel rods iii. Profilometry iv. Fuel rod length v. Fuel assembly length b. Using the standard and Optimized ZIRLOTM database including the most recent LTA data, confirm applicability with currently approved fuel performance models (e.g., measured vs. predicted).

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

Westinghouse has provided the NRC with information related to test data and models in the letters referenced in Section 7 of this enclosure

[References 3-7, 14].LTA measured data and favorable results from visual examinations of once, twice, and thrice-burned LTAs 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 the above mentioned letters, Westinghouse has Seabrook Nuclear Plant SBK-L-13070 Docket No. 50-443 Enclosure License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Page 8 of 14 Optimized ZIRLO Fuel Rod Cladding fulfilled its obligation to provide additional data from the Optimized ZIRLOTM 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 ZIRLOTM database including the most recent Vogtle data, confirm applicability with currently approved fuel performance models (e.g., level of conservatism in Westinghouse rod pressure analysis, measured vs.predicted, predicted minus measured vs. tensile and compressive stress).Confirmation of the approved models' applicability up through the projected end of cycle bumup for the Optimized ZIRLOTM fuel rods must be completed prior to their initial batch loading and prior to the startup of subsequent cycles. For example, prior to the first batch application of Optimized ZIRLOTM, sufficient LTA data may only be available to confirm the models' applicability up through 45 GWd/MTU. In this example, the licensee would need to confirm the models up through the end of the initial cycle. Subsequently, the licensee would need to confirm the models, based upon the latest LTA data, prior to re-inserting the Optimized ZIRLOTM fuel rods in future cycles. Based upon the LTA schedule, it is expected that this issue may only be applicable to the first few batch implementations since sufficient LTA data up through the burnup limit should be available within a few years.RESPONSE:

Westinghouse has provided the NRC with information related to test data and models in References 3 -7 and 14.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 the above mentioned letters, Westinghouse has fulfilled its obligation to provide additional data from the Optimized ZIRLOTM 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.

Seabrook Nuclear Plant SBK-L-13070 Docket No. 50-443 Enclosure License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Page 9 of 14 Optimized ZIRLO Fuel Rod Cladding 8. The licensee shall account for the relative differences in unirradiated strength (YS and UTS) between Optimized ZIRLOTM and standard ZIRLO in claddingand structural analyses until irradiated data for Optimized ZIRLOTM have been collected and provided to the NRC staff.a. For the Westinghouse fuel design analyses: 1. The measured, unirradiated Optimized ZIRLOTM strengths shall be used for BOL analyses.ii. Between BOL up to a radiation fluence of 3.0 x 1021 n/cm 2 (E> 1MeV), pseudo-irradiated Optimized ZIRLOTM strength set equal to linear interpolation between the following two strength level points: At zero fluence, strength of Optimized ZIRLOTM equal to measured strength of Optimized ZIRLOTM and at a fluence of 3.0 x 1021 n/cm 2 (E> 1 MeV), irradiated strength of standard ZIRLO at the fluence of 3.0 x 1021 n/cm 2 (E>IMeV) minus 3 ksi.iii. During subsequent irradiation from 3.0 x 1021 n/cm 2 up to 12 x 1021 n/cm 2 , the differences in strength (the difference at a fluence of 3 x 1021 n/cm 2 due to tin content) shall be decreased linearly such that the pseudo-irradiated Optimized ZIRLOTM strengths will saturate at the same properties as standard ZIRLOO at 12 x 1021 n/cm 2.b. For the CE fuel design analyses, the measured, unirradiated Optimized ZIRLOTM strengths shall be used for all fluence levels (consistent with previously approved methods).RESPONSE:

Seabrook uses a Westinghouse fuel design, and therefore, condition 8.b does not apply.The fuel analysis of Optimized ZIRLOTM 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 ZIRLOTM strengths have been collected and provided to the NRC.NextEra will confirm that the requirements of this condition will be met as applicable to Seabrook as part of the normal reload design process.9. As discussed in response to RAI #21, for plants introducing Optimized ZIRLOTM that are licensed with LOCBART or STRIKIN-II and have a limiting PCT that occurs during blowdown or early reflood, the limiting Seabrook Nuclear Plant SBK-L-13070 Docket No. 50-443 Enclosure License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Page 10 of 14 Optimized ZIRLO Fuel Rod Cladding LOCBART or STRIKIN-II calculation will be rerun using the specified Optimized ZIRLOTM material properties.

Although not a condition of approval, the NRC staff strongly recommends that, for future evaluations, Westinghouse update all computer models with Optimized ZIRLOTM specific material properties.

RESPONSE:

Seabrook is not licensed with LOCBART or STRIKIN-II.

Therefore, this Condition does not apply.10. Due to the absence of high temperature oxidation data for Optimized ZIRLOTM, the Westinghouse coolability limit on PCT during the locked rotor event shall be [proprietary limits included in topical report and proprietary version of safety evaluation].

RESPONSE:

For implementation of Optimized ZIRLO T M fuel cladding, the peak cladding temperature (PCT) calculated for the locked rotor event will be assessed relative to the Westinghouse Optimized ZIRLOTM PCT limit. For subsequent core reload designs, the calculated PCT will be reassessed as part of the normal reload design process.

4.0 REGULATORY EVALUATION

4.1 Applicable

Regulatory Requirements

/ Criteria 0 10 CFR 50.46 provides acceptance criteria for emergency core cooling systems for light-water nuclear power reactors.0 Appendix K to Part 50 establishes the required and acceptable features of the ECCS evaluation models 0 By letter dated June 10, 2005, the NRC staff issued a safety evaluation approving Addendum 1 to Westinghouse Topical Report WCAP-12610-P-A and CENPD-404-P-A, "Optimized ZIRLOTM,

wherein the NRC staff approved the use of Optimized ZIRLOTM as an acceptable fuel cladding material for Westinghouse and Combustion Engineering (CE) fuel designs NextEra evaluated the proposed changes to determine whether applicable regulations and requirements continue to be met. This determination found that the proposed change to allow the use of Optimized ZIRLOTM fuel rod cladding material requires an exemption from 10 CFR 50.46, Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors; and 10 CFR 50, Appendix K, ECCS Evaluation Models.

Seabrook Nuclear Plant SBK-L-13070 Docket No. 50-443 Enclosure License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Page 11 of 14 Optimized ZIRLO Fuel Rod Cladding Attachment 1 provides the basis and justification for exemption from these regulations.

4.2 Precedent

As part of the industry focus to minimize the potential for fuel failure, several licensees have received staff approval to use Optimized ZIRLOTM.Dominion has received approval at North Anna Power Station, Units 1 and 2, Surry Power Station, Units 1 and 2, [References 8-10] and most recently, Millstone Power Station, Unit 3 [Reference 11]. Indiana Michigan Power Company has also received approval at D.C. Cook Nuclear Plant, Unit 1 and 2 [References 12-13].4.3 No Significant Hazards Determination NextEra Energy Seabrook, LLC (NextEra) proposes to revise the Seabrook Station Technical Specifications (TS) to allow the use of Optimized ZIRLOTM fuel rod cladding material.

The proposed changes would revise TS 5.3.1 to add Optimized ZIRLOTM to the approved fuel rod cladding materials and TS 6.8.1.6.b to add Westinghouse Electric Company LLC (Westinghouse) topical report WCAP-12610-P-A

&CENPD-404-P-A, Addendum 1-A "Optimized ZIRLOTM,

to the NRC-approved analytical methods used to determine the core operating limits.NextEra has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) 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?

Response:

No.The proposed change would allow the use of Optimized ZIRLOTM clad nuclear fuel in the reactors.

The NRC approved topical report WCAP- 12610-P-A and CENPD-404-P-A, Addendum 1-A"Optimized ZIRLOTM,

prepared by Westinghouse Electric Company LLC (Westinghouse), addresses Optimized ZIRLOTM and demonstrates that Optimized ZIRLOTM has essentially the same properties as currently licensed ZIRLO. The fuel cladding itself is not an accident initiator and does not affect accident probability.

Use of Optimized ZIRLOTM fuel cladding will continue to meet all 10 CFR 50.46 acceptance criteria and, Seabrook Nuclear Plant SBK-L-13070 Docket No. 50-443 Enclosure License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Page 12 of 14 Optimized ZIRLO Fuel Rod Cladding therefore, will not increase the consequences of an accident.Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response:

No.Use of Optimized ZIRLOTM clad fuel will not result in changes in the operation or configuration of the facility.

Topical Report WCAP- 12610-P-A and CENPD-404-P-A demonstrated that the material properties of Optimized ZIRLOTM are similar to those of standard ZIRLO. Therefore, Optimized ZIRLOTM fuel rod claddini will perform similarly to those fabricated from standard ZIRLO , thus precluding the possibility of the fuel cladding 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 ZIRLOTM are not significantly different from those of standard ZIRLO. Optimized ZIRLOTM 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, where the slight difference in Optimized ZIRLOTM material properties relative to standard ZIRLOTM could have some impact on the overall accident scenario, plant-specific LOCA analyses using Optimized ZIRLOTM properties will demonstrate that the acceptance criteria of 10 CFR 50.46 have been satisfied.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.Based on the above, NextEra concludes that the proposed amendment presents no significant hazards consideration under the standards set forth Seabrook Nuclear Plant SBK-L- 13070 Docket No. 50-443 Enclosure License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Page 13 of 14 Optimized ZIRLO Fuel Rod Cladding in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

4.4 Conclusion

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3)the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.5.0 ENVIRONMENTAL CONSIDERATION A review 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 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 a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

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

6.0 REFERENCES

1. WCAP- 12610-P-A

& CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOTM,

July 2006.2. Letter from H. N. Berkow (USNRC) to J. A. Gresham (Westinghouse), "Final Safety Evaluation for Addendum 1 to Topical Report WCAP- 12610-P-A

&CENPD-404-P-A, 'Optimized ZIRLO T M','" June 10, 2005.3. Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance with WCAP- 12610-P-A

& CENPD-404-P-A, Addendum 1-A, 'Optimized ZIRLOTM'," LTR-NRC-07-1, January 4, 2007.4. Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance with WCAP- 12610-P-A

& CENPD-404-P-A, Addendum 1-A, 'Optimized ZIRLOTM'," LTR-NRC-07-58, November 6, 2007.

Seabrook Nuclear Plant SBK-L- 13070 Docket No. 50-443 Enclosure License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Page 14 of 14 Optimized ZIRLO Fuel Rod Cladding 5. Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance with WCAP- 12610-P-A

& CENPD-404-P-A, Addendum 1-A, 'Optimized ZIRLOTM'," LTR-NRC-07-58, Rev. 1, February 5, 2008.6. Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance of WCAP- 12610-P-A

& CENPD-404-P-A Addendum 1-A, 'Optimized ZIRLO T M'," LTR-NRC-08-60, December 30, 2008.7. Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance of WCAP- 12610-P-A

& CENPD-404-P-A Addendum 1-A, 'Optimized ZIRLO T M'," LTR-NRC-10-43, July 26, 2010.8. J. S. Wiebe to D. A. Heacock, "North Anna Power Station, Unit Nos. 1 and 2, Exemption from the Requirements of Title 10 of the Code of Federal Regulations, Part 50, Section 50.46 and Appendix K (TAC Nos. ME3885 and ME3886)," Dominion Serial No.11-182, Accession No. ML 10601196, March 23, 2011.9. K. Cotton to D. A. Heacock, "Surry Power Station, Unit Nos. 1 and 2, Issuance of Amendments Regarding the Use of Optimized ZIRLO Fuel Rod Cladding (TAC Nos. ME3343 and ME 3344)," Dominion Serial No.10-669, Accession No. ML103360256, December 22, 2010 10. K. Cotton to D. A. Heacock, "Surry Power Station, Unit Nos. 1 and 2, Corrections to Amendments Regarding the Use of Optimized ZIRLOTM Fuel Rod Cladding (TAC Nos. ME3343 and ME 3344)," Dominion Serial No.10-755, December 23, 2010.11. J. Kim to D. A. Heacock, "Millstone Power Station Unit No. 3 -Issuance of Amendment Re: The Use of Optimized ZIRLOTM Fuel Rod Cladding (TAC No. ME7663),"Accession No. ML12236A396, September 24, 2012.12. P .S. Tam to L. J. Weber, "Donald C. Cook Nuclear Plant, Unit 1 -Issuance of Amendment Re: Use of Optimized ZIRLOTM Fuel Rod Cladding Material (TAC No. ME5183)," Accession No. ML 11610020, August 25, 2011.13. P. S. Tam to L. J. Weber, "Donald C. Cook Nuclear Plant, Unit 2 -Issuance of Amendment Re: Use of Optimized ZIRLOTM Fuel Rod Cladding Material (TAC No. ME7323)," Accession No. ML 12138A398, August 23, 2012.14. Letter from James A. Gresham (Westinghouse) to USNRC, "SER Compliance of WCAP- 12610-P-A

& CENPD-404-P-A Addendum 1 -A, 'Optimized ZIRLOTM'," LTR-NRC-13-6, February 25, 2013.

Seabrook Nuclear Plant Docket No. 50-443 License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Optimized ZIRLO Fuel Rod SBK-L-13070 Attachment I Page 1 of 6 ATTACHMENT 1 REQUEST FOR EXEMPTION FROM THE PROVISIONS OF 10 CFR 50.46 AND 10 CFR PART 50 APPENDIX K TO ALLOW USE OF OPTIMIZED ZIRLO T M FUEL CLADDING Seabrook Nuclear Plant SBK-L- 13070 Docket No. 50-443 Attachment I License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Page 2 of 6 Optimized ZIRLO Fuel Rod Cladding 1.0 Purpose and Scope NextEra Energy Seabrook, LLC (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 ZIRLOTM fuel rod cladding in future core reload applications for Seabrook Station. 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 concentration, and cladding oxidation for the metal-water reaction.The Baker-Just equation assumed the use of a zirconium alloy different than Optimized ZIRLOTM material.

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

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

2.0 Background

Information Optimized ZIRLOTM was developed to meet the needs of longer operating cycles with increased fuel discharge burnup and fuel duty. Optimized ZIRLO M fuel cladding is different from standard ZIRLOO 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 ZIRLOTM 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.

3.0 Technical

Justification of Acceptability Westinghouse Electric Company LLC (Westinghouse) topical report WCAP-12610-P-A

& CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOTM,, (Reference 1), provides the details and results of testing of Optimized ZIRLOTM material compared to standard ZIRLO material as well as the material properties to be used in various models and methodologies when analyzing Optimized ZIRLOTM fuel rod cladding.

The Nuclear Regulatory Commission (NRC) Safety Evaluation (SE) (Reference

2) for the topical report contains ten conditions and limitations.

The first condition requires an exemption from 10 CFR 50.46 and 10 CFR Part 50, Appendix K (which is being requested via this letter). Westinghouse has provided the NRC with information related to test data and models (References 3 thru 8) to address conditions and limitations 6 and 7. Condition Seabrook Nuclear Plant SBK-L-13070 Docket No. 50-443 Attachment I License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Page 3 of 6 Optimized ZIRLO Fuel Rod Cladding and limitation 9 does not apply because Seabrook is not licensed with LOCBART or STRIKIN-II.

The remaining conditions and limitations are addressed in the Seabrook Technical Specification (TS) changes and evaluations required to support core reload activities.

Since plant-specific TS changes are required prior to utilizing Optimized ZIRLOTM fuel rod cladding, no new commitments are necessary to support NRC approval of this exemption request.The reload evaluations will ensure that acceptance criteria are met for insertion of assemblies with fuel rods clad with Optimized ZIRLOTM material.

These assemblies will be evaluated using NRC approved methods and models to address the use of Optimized ZIRLOTM fuel rod cladding.4.0 Justification of Exemption 10 CFR 50.12, "Specific exemptions," states that the NRC may grant exemptions from the requirements of the regulations of this part provided two conditions are met. These are: 1) authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security; and 2) the Commission will not consider granting an exemption unless special circumstances are present.The requested exemption to allow the use of Optimized ZIRLOTM fuel rod cladding material rather than Zircaloy or ZIRLO material for core reload applications at Seabrook Unit 1 satisfies these criteria as described below.Condition 1: 1. This exemption is authorized by law This exemption allows the use of Optimized ZIRLOTM fuel rod cladding material at Seabrook.

As stated above, 10 CFR 50.12 allows the NRC to grant exemptions from the requirements of 10 CFR 50. Granting this proposed exemption would not result in a violation of the Atomic Energy Act of 1954, as amended, or the Commission's regulations.

Therefore, the exemption is authorized by law. Further, by submitting this exemption request, NextEra does not seek an exemption from the acceptance and analytical criteria of 10 CFR 50.46 and 10 CFR Part 50, Appendix K. The intent of the request is solely to allow the use of criteria set forth in these regulations for application to the Optimized ZIRLOTM fuel rod cladding material.2. This exemption will not present an undue risk to public health and safety The reload evaluations will ensure that acceptance criteria are met for the insertion of assemblies with fuel rods clad with Optimized ZIRLOTM material.

Fuel assemblies using Optimized ZIRLOTM fuel rod cladding will be evaluated using NRC-approved analytical methods and plant-specific models to address the changes in the cladding Seabrook Nuclear Plant SBK-L- 13070 Docket No. 50-443 Attachment 1 License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Page 4 of 6 Optimized ZIRLO Fuel Rod Cladding material properties.

The safety analysis for Seabrook 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 aforementioned regulations to an improved fuel rod cladding material.

All the requirements and acceptance criteria will be maintained.

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

Use of full regions of Optimized ZIRLOTM fuel rod cladding in the Seabrook core will not affect plant operations and is consistent with common defense and security.Condition 2: Presence of Special Circumstances 10 CFR 50.12(a)(2) states that the NRC will not consider granting an exemption to the regulations unless special circumstances are present. The requested exemption meets the special circumstances of 10 CFR 50.12(a)(2)(ii) which states that, "Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule." In this particular circumstance, application of the subject regulations is not necessary to achieve the underlying purpose of the rule.10 CFR 50.46 identifies acceptance criteria for ECCS performance at nuclear power plants. Due to the similarities in the properties of Optimized ZIRLOTM material and standard ZIRLO material, the current ECCS analysis approach remains applicable.

Westinghouse will perform an evaluation of the Seabrook Unit 1 core using Loss of Coolant Accident (LOCA) methods approved for the site to ensure that assemblies with Optimized ZIRLOTM fuel rod cladding material meet all LOCA safety criteria.The intent of 10 CFR Part 50, Appendix K, paragraph I.A.5 is to apply an equation for rates of energy release, hydrogen generation, and cladding oxidation from a metal-water reaction that conservatively bounds all post-LOCA scenarios (i.e., the Baker-Just equation).

Application of the Baker-Just equation has been demonstrated to be appropriate for the Optimized ZIRLOTM alloy. Due to the similarities in the composition of the Optimized ZIRLOTM and standard ZIRLO fuel rod cladding materials, the application of the Baker-Just equation will continue to conservatively bound all post-LOCA scenarios.

Seabrook Nuclear Plant SBK-L-13070 Docket No. 50-443 Attachment 1 License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Page 5 of 6 Optimized ZIRLO Fuel Rod Cladding 5.0 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 Optimized ZIRLOTM fuel rod cladding material since Optimized ZIRLOTM material has a slightly different composition than Zircaloy or ZIRLOmaterial.

With the approval of this exemption request, these regulations will be applied to Optimized ZIRLOTM fuel rod cladding.In order to support the use of Optimized ZIRLOTM fuel rod cladding material, an exemption from the requirements of 10 CFR 50.46 and 10 CFR Part 50, Appendix K is requested.

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

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

6.0 References

1. WCAP-12610-P-A

& CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOTm," July 2006.2. Letter from H. N. Berkow (USNRC) to J. A. Gresham (Westinghouse), "Final Safety Evaluation for Addendum 1 to Topical Report WCAP- 12610-P-A

& CENPD-404-P-A, 'Optimized ZIRLO T M',"' June 10, 2005.3. Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance with WCAP-12610-P-A

& CENPD-404-P-A, Addendum 1-A, 'Optimized ZIRLOTM',

LTR-NRC 1, January 4, 2007.4. Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance with WCAP- 126 10-P-A & CENPD-404-P-A, Addendum 1 -A, 'Optimized ZIRLO T M'," LTR-NRC-07-5 8, November 6, 2007.5. Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance with WCAP-12610-P-A

& CENPD-404-P-A, Addendum 1-A, 'Optimized ZIRLO T M','" LTR-NRC-07-58, Rev. 1, February 5, 2008.6. Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance of WCAP-12610-P-A

& CENPD-404-P-A Addendum 1-A, 'Optimized ZIRLOTM','" LTR-NRC-08-60, December 30, 2008.

Seabrook Nuclear Plant Docket No. 50-443 License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Optimized ZIRLO Fuel Rod Cladding SBK-L- 13070 Attachment I Page 6 of 6 7. Letter from J. A. Gresham (Westinghouse) to USNRC, "SER Compliance of WCAP-12610-P-A

& CENPD-404-P-A Addendum 1-A, 'Optimized ZIRLOTM'," LTR-NRC- 10-43, July 26, 2010.8. Letter from James A. Gresham (Westinghouse) to USNRC, "SER Compliance of WCAP- 12610-P-A

& CENPD-404-P-A Addendum 1 -A, 'Optimized ZIRLOTM',

LTR-NRC-13-6, February 25, 2013.

Seabrook Nuclear Plant Docket No. 50-443 License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Optimized ZIRLO Fuel Rod Cladding SBK-L- 13070 Attachment 2 Page I of 4 ATTACHMENT 2 TECHNICAL SPECIFICATION MARKUPS Seabrook Nuclear Plant Docket No. 50-443 License Amendment Request 13-04 & 10 CFR 50.12 Exemption Request Optimized ZIRLO Fuel Rod Cladding SBK-L- 13070 Attachment 2 Page 2 of 4 Proposed Technical Specification Changes (Mark-Up)The attached markups reflect the currently issued version of the TS and Facility Operating License. At the time of submittal, the Facility Operating License was revised through Amendment No. 136.Listed below are the license amendment requests that are awaiting NRC approval and may impact the currently issued version of the Facility Operating License affected by this LAR.LAR Title NextEra Energy Date Seabrook Letter Submitted 11-04 Changes to the Technical Specifications for New and SBK-L-1 1245 01/30/2012 Spent Fuel Storage 13-01 Application for Administrative Change and SBK-L-13028 03/01/2013 Corrections to the Technical Specifications 13-02 Application to Revise Technical Specifications to SBK-L-13030 03/27/2013 Adopt TSTF-5 10, "Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection," Using the Consolidated Line Item Improvement Process 13-03 Application for Technical Specification Change SBK-L-13071 05/28/2013 Regarding Risk-Informed Justifications for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program The following TS pages are included in the attached markup: Technical Page Specification Title 5.3.1 Reactor Core -Fuel Assemblies 5-9 6.8.1.6.b Core Operating Limits Report 6-20 DESIGN FEATURES DESIGN PRESSURE AND TEMPERATURE 5.2.2 The containment building is designed and shall be maintained for a maximum internal pressure of 52.0 psig and a temperature of 296 0 F.5.3 REACTOR CORE ZIRLO, or Optimized ZIRLOTM FUEL ASSEMBLIES 5.3.1 The reactor shall contain 193 fu I slsemblies.

Each assembly shall consist of a matrix of cylindrical Z',RLG or Zircaloy-4 ad fuel rods with an initial composition of natural or slightly enriched uranium dioxide (U0 2) as fuel material.

Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with NRC-approved applications of fuel rod configurations, may be used. Fuel assemblies shall be limited to those fuel designs that have been analyzed with applicable NRC staff-approved codes and methods and shown by tests or analyses to comply with all fuel safety design bases. A limited number of lead test assemblies that have not completed representative testing may be placed in nonlimiting core regions. Reload fuel shall be similar in physical design to the initial core loading and shall have a maximum enrichment of 5.0 weight percent U-235.CONTROL ROD ASSEMBLIES 5.3.2 The core shall contain 57 full-length control rod assemblies.

The full-length control rod assemblies shall contain a nominal 142 inches of absorber material.

The nominal values of absorber material shall be 80% silver, 15% indium, and 5% cadmium. All control rods shall be clad with stainless steel tubing.5.4 REACTOR COOLANT SYSTEM DESIGN PRESSURE AND TEMPERATURE 5.4.1 The Reactor Coolant System is designed and shall be maintained:

a. In accordance with the Code requirements specified in Section 5.2 of the FSAR, with allowance for normal degradation pursuant to the applicable Surveillance Requirements, b. For a pressure of 2485 psig, and c. For a temperature of 6501F, except for the pressurizer which is 6801F.VOLUME 5.4.2 The total water and steam volume of the Reactor Coolant System is 12,255 cubic feet at a nominal Tavg of 588.5°F.5.5 (THIS SPECIFICATION NUMBER IS NOT USED)SEABROOK -UNIT 1 5-9 Amendment No. 53

[WCAP-12610-P-A

& CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOTM", July 2006. 1 ADMINISTRATIVE CONTROLS 6.8.1.6.b (Continued)

12. NYN-95048, Letter from T. C. I eigenbaum (NAESCo) to NRC, "License Amendment Request 95-05: P sitive Moderator Temperature Coefficient", May 30, 1995.Methodology for Specification:

3.1.1.3 -Moderator Tem erature Coefficient

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

Methodology for Specification:

3.2.2 -Heat Flux Hot Channel Factor 14. WCAP-10216-P-A, Revision 1A (Proprietary), "Relaxation of Constant Axial Offset Control FQ Surveillance Technical Specification", February, 1994.Methodology for Specification:

3.2.1 -AXIAL FLUX DIFFERENCE 3.2.2 -Heat Flux Hot Channel Factor 15. WCAP-9272-P-A, (Proprietary), "Westinghouse Reload Safety Evaluation Methodology", July, 1985.Methodology for Specifications:

2.1 -Safety Limits 3.1.1.1 -SHUTDOWN MARGIN for MODES 1,2,3, and 4 3.1.1.2 -SHUTDOWN MARGIN for MODE 5 3.1.1.3 -Moderator Temperature Coefficient 3.1.2.7 -Isolation of Unborated Water Sources -Shutdown 3.1.3.5 -Shutdown Rod Insertion Limit 3.1.3.6 -Control Rod Insertion Limits 3.2.1 -AXIAL FLUX DIFFERENCE 3.2.2 -Heat Flux Hot Channel Factor 3.2.3 -Nuclear Enthalpy Rise Hot Channel Factor 3.2.5 -DNB Parameters 3.5.1.1 -Accumulators for MODES 1, 2, and 3 3.5.4 -Refueling Water Storage Tank for MODES 1, 2, 3, and 4 3.9.1 -Boron Concentration

16. WCAP-13749-P-A, (Proprietary) "Safety Evaluation Supporting the Conditional Exemption of the Most Negative Moderator Temperature Coefficient Measurement," March, 1997.Methodology for Specifications:

3.1.1.3 -Moderator Temperature Coefficient SEABROOK -UNIT 1 6-20 Amendment No. 66, 88, 104, 107, 115