ML17129A451

Submittal of Proposed License Amendment Request for Spent Fuel Storage and New Fuel Storage

ML17129A451
Person / Time
Site:	North Anna
Issue date:	05/02/2017
From:	Mark D. Sartain Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
Download: ML17129A451 (101)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 10 CFR 50.90

. May 2, 2017 U.S. Nuclear Regulatory Commission Serial No.: 16-383 Attention: Document Control Desk NRNDEA RO Washington, DC 20555 Docket Nos.: 50-338/339 License Nos.: NPF-4/7 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

NORTH ANNA POWER STATION UNITS 1 AND 2 PROPOSED LICENSE AMENDMENT REQUEST FOR SPENT FUEL STORAGE AND NEW FUEL STORAGE Pursuant to 10 CFR 50.90, Dominion is submitting a license amendment request to revise Technical Specifications (TS) 3.7.18, "Spent Fuel Pool Storage" and TS 4.3.1 "Criticality."

Conforming changes are proposed to Technical Specifications Bases (TSB) 83.7.18. A supporting criticality safety evaluation for fuel assembly storage in the North Anna Power Station (NAPS) Spent Fuel Pool (SFP) storage racks and the New Fuel Storage Racks (NFSR) was performed for the proposed TS change. The criticality safety evaluation substantiates increasing the fuel assembly maximum uranium 235 (U-235) enrichment from 4.6 weight percent to 5.0 weight percent.

The proposed amendment implements the following conditions associated with fuel assembly storage at NAPS:

• Increase the maximum licensed fuel assembly enrichment from 4.6 weight percent U-235 to 5.0 weight percent U-235.

• Revise allowed storage patterns and initial enrichmenUburnup/cooling time for fuel assemblies in the SFP to meet kett requirements under normal and accident conditions as follows:

o New Region 1 will require that fuel assemblies be stored in a new Checkerboard arrangement (2-out-of-4 storage), but will have no burnup curve.

o New Region 2 will have two new burnup curves and all Re.gion 2 storage locations will be available for fuel assembly storage. One of the new burnup curves will also incorporate assembly cooling time for determining whether a fuel assembly is permitted to be stored in Region 2.

• Permit the storage of any fuel assembly containing a full length Rod Cluster Control Assembly (RCCA) in Region 2 without regard to the new burnup curves.

Attachment 6 contains information that is being withheld from public

• disclosure under 10 CFR 2.390. Upon separation from Attachment 6, this ..;{;;;:$'.

letter is decontrolled.

I Serial No.16-383 Docket Nos.: 50-338/339 Page 2 of 5 Information provided in the attachments to this letter is summarized below:

- Attachment 1 provides an evaluation of the proposed TS changes.

- Attachment 2 provides marked-up Technical SpeCifications pages.

- Attachment 3 provides proposed Technical Specifications changes pages.

- Attachment 4 provides marked-up and proposed Technical Specifications Bases changes pages (for information only).

- Attachment 5 contains the Criticality Safety Evaluation Checklist.

- Attachment 6 contains the Criticality Safety Evaluation Report (Proprietary).

- Attachment 7 contains the Criticality Safety Evaluation Report (Non-proprietary).

- Attachment 8 contains the Affidavit of AREVA NP, Inc. (AREVA) for withholding proprietary Information from public disclosure.

- Attachment 9 contains the Westinghouse Electric Company, LLC (Westinghouse) application for withholding proprietary information from public disclosure CAW 4510 and accompanying affidavit. (Westinghouse information only)

- Attachment 10 contains the Affidavit of Electric Power Research Institute, Inc.

(EPRI) and AREVA for withholding proprietary information from public disclosure.

- Attachment 11 contains the Westinghouse Electric Company, LLC (Westinghouse) application for withholding proprietary information from public disclosure CAW 4513 and accompanying affidavit. (regarding information co-owned with EPRI)

Since Attachment 6 contains information proprietary to AREVA NP, Inc. (AREVA),

Westinghouse, and EPRI, it is supported by affidavits signed by the owners of the information. The affidavits set forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390.

Accordingly, it is respectfully requested that the proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390.

Dominion has evaluated the proposed amendment and determined that it does not involve a significant hazards consideration as defined in 10 CFR 50.92. The basis for this determination is included in Attachment 1. Dominion has also determined that operation with the proposed change will not result in any significant increase in the amount of effluents that may be released offsite or any significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed amendment is eligible for categorical exclusion from an environmental assessment as set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed change.

The proposed TS change has been reviewed and approved by the NAPS Facility Safety Review Committee.

Serial No.16-383 Docket Nos.: 50-338/339 Page 3 of 5 Dominion requests approval of the proposed amendment by April 1, 2018. Once approved, the amendment will be implemented within 6 months (to allow time to shuffle fuel in the SFP to conform to the revised TS).

Should you have any questions in regard to this submittal, please contact Diane Aitken at (804) 273-2694.

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering and Fleet Support 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 and Fleet Support of Virginia Electric and Power Company. 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 ,:/~day of .d!Ay , 2017.

My Commission Expires: 5 *. ~J - JI! .~. L~

Notary Public Commitments made in this letter: None

Serial No.16-383 Docket Nos.: 50-338/339 Page 4 of 5 Attachments:

1. Discussion of Change

2. Marked-up Technical Specifications Pages

3. Proposed Technical Specifications Pages

4. Marked-up and Proposed Technical Specifications Bases Pages (for information only)

5. Criticality Safety Evaluation Checklist

6. Criticality Safety Evaluation Report - (Proprietary)

7. Criticality Safety Evaluation Report - (Non-proprietary)

8. Affidavit of AREVA NP, Inc.

9. Affidavit of Westinghouse Electric Company, LLC (Westinghouse information only)

10. Affidavit of Electric Power Research Institute, Inc. and AREVA

11. Affidavit of Westinghouse Electric Company, LLC (regarding information co-owned with EPRI)

Serial No.16-383 Docket Nos.: 50-338/339 Page 5 of 5 cc: U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, GA 30303-1257 State Health Commissioner Virginia Department of Health James Madison Building - 7th floor 109 Governor Street Suite 730 Richmond, VA 23219 Ms. Brenda Mozafari NRC Project Manager - North Anna U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 Ms. Karen Cotton-Gross NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector North Anna Power Station Mr. J. E. Reasor, Jr.

Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd.

Suite 300 Glen Allen, VA 23060

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 1 of 26 Attachment 1 DISCUSSION OF CHANGE VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 2 of 26 Discussion of Change Table of Contents 1.0 Summary Description .............................................................................................3 2.0 Detailed Description of Change .............................................................................5 2.1 TS 3.7.18 - Spent Fuel Pool Storage ................................................................. 5 2.2 TS 4.3 - Fuel Pool Storage ................................................................................7 3.0 Discussion ..............................................................................................................8 3.1 Introduction .........................................................................................................8 3.2 Current North Anna Spent Fuel Pool Configuration ............................................ 9 4.0 Technical Evaluation Summary ............................................................................ 10 4.1 Introduction ....................................................................................................... 10 4.2 Fuel Storage Criticality Analysis - General ......................................................... 10 4.3 New Fuel Storage Racks Criticality Analysis - Normal Storage and Accident Conditions .................................................................................................................. 11 4.4 Spent Fuel Pool Criticality Safety Evaluation - Normal Storage Conditions ...... 11 4.5 Spent Fuel Pool Criticality Safety Evaluation - Accident Conditions ................. 12 4.6 Boron Dilution ................................................................................................... 13

4. 7 Storage of Non-fuel Components and Non-standard Fuel Assemblies ............. 13 4.8 Spent Fuel Pool Storage - Other Items ............................................................ 14 4.9 Implementation Considerations ........................................................................ 17 4.10 Conclusions ................................................................................................... 18 5.0 Regulatory Evaluation .......................................................................................... 19 5.1 Applicable Regulatory Requirements and Criteria ............................................ 19 5.2 No Significant Hazards Consideration .............................................................. 19 5.3 Precedents .......................................................................................................24 6.0 Environmental Considerations ............................................................................. 25 7.0 References ...........................................................................................................26

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 3 of 26 1.0 Summary Description Dominion hereby proposes to amend Operating Licenses NPF-4 and NPF-7 by incorporating the attached proposed changes into the Technical Specifications (TS) of North Anna Power Station (NAPS). Dominion is proposing to change the following TS:

• TS 3.7.18 Spent Fuel Pool Storage o SR 3.7.18.1 Surveillance Requirements o Figure 3.7.18-1: Typical Region 1 Checkerboard o Figure 3.7.18-2: Minimum Burnup Requirements For Region 2 With No Credit For Cooling o Figure 3. 7 .18-3: Minimum Burn up Requirements For Region 2 for Assemblies Cooled 3 Years or More

• TS 4.3 Fuel Storage o TS 4.3.1 Criticality The associated Bases for TS 3.7.18 are also being modified to address the proposed changes and are provided for information only. Changes to the TS Bases are controlled in accordance with the NAPS TS Bases Control Program.

Note that the Spent Fuel Pool (SFP) racks contain Boraflex, which at present is not credited as a neutron absorber. This proposed change will also not credit Boraflex.

In order to meet the SFP criticality requirements, the following changes are* being proposed:

• Increase the licensed fuel assembly maximum U-235 enrichment from 4.6 weight percent U-235 to 5.0 weight percent U-235 (this change also requires that the New Fuel Storage Racks {NFSR} be reanalyzed to accept this higher enrichment).

• Revise allowed storage patterns for fuel assemblies in the SFP to meet keff requirements under normal and accident conditions:

o Region 1 will have a checkerboard arrangement (2-out-of-4 storage with other restrictions described later).

o Region 2 will have all storage locations available for storage of fuel assemblies.

• Update the surveillance requirement for storing fuel assemblies in Region 1 and Region 2.

• Remove burnup/enrichment requirements for storing fuel assemblies in new Region 1.

• Include new initial enrichment/burnup curves for new Region 2, with and without

• cooling time consideration.

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 4of26

• Permit the storage of any fuel assembly containing a full length Rod Cluster Control Assembly (RCCA) in Region 2 without regard to the Region's burnup curves.

The proposed change has been reviewed and confirmed to accommodate fuel currently in the SFP and NFSR and fuel assembly designs anticipated in the future.

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 5 of 26 2.0 Detailed Description of Change

2. 1 TS 3. 7. 18 - Spent Fuel Pool Storage Technical Specification 3.7.18 currently has 3 subparts, (a), (b) and (c), which specify initial enrichment and burn up requirements (Figure 3. 7 .18-1) for storage of spent fuel assemblies in the matrix storage configuration specified (Figure 3. 7 .18-2). The proposed change to the TS changes the fuel assembly storage configuration to 2 Regions. The proposed change places no initial enrichment and burnup restrictions on Region 1 allowing all fuel assemblies to be stored in Region 1 under a specified 2-out-of-4 storage checkerboard arrangement. The proposed change does place new initial enrichment, burnup, and cooling time restrictions on Region 2, but allows fuel assembly storage in all Region 2 locations for fuel assemblies that meet these requirements. The proposed change also permits storage of fuel assemblies in Region 2 without the initial enrichmenUburnup/cooling time restrictions if the fuel assembly contains a full length RCCA.

The proposed changes to the TS are specified below:

LCO 3.7.18 Limiting Condition of Operation (LCO) 3.7.18(a), (b), and (c) are removed and replaced with new LCO 3.7.18(a) and (b). The proposed change replaces the fuel assembly storage arrangement (TS Figure 3.7.18-1) and replaces the existing burn up curve (TS Figure 3. 7 .18-2) with a new checkerboard configuration (Region 1), and two (2) new burn up curves (Region 2).

Region 1 characteristics include:

• A new checkerboard configuration (new Figure 3. 7 .18-1) which includes storage locations in which no fuel assembly can be stored (2-out-of-4 storage):

o A RCCA and/or a cell blocker may be stored in an empty location because RCCAs are strong neutron absorbers and cell blockers are located above the fuel.

• The four corners of a Region 1 "block" shall be an empty location.

• A minimum of two Region 2 rows between Region 1 blocks.

• A Region 1 block shall not cross a spent fuel rack boundary where a rack module is adjacent to another rack module. Thus, a Region 1 block is contained within a single spent fuel rack:

o Rack modules that are adjacent to the SFP wall may credit the wall region as empty cells for the purposes of meeting the Region 1 requirements of proposed LCO 3.7.18.a.ll.i and 3.7.18.a.ll.iii since the reactivity of the wall region is bounded by the Region 1 checkerboard storage arrangement.

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 6 of 26

• A Region 1 block must not include SFP storage locations AA21, AA22, 8821, 8822, CC21, and CC22.

• No burnup curve; all fuel assemblies may be stored in Region 1 except in those locations marked as "Empty" in the checkerboard storage arrangement.

Region 2 characteristics include:

• All Region 2 fuel storage locations are available for fuel assembly storage.

• Irradiated fuel assemblies with a combination of initial enrichment, burnup, and cooling time in the "Acceptable" domain of the new burnup curves (Figure 3.7.18-2 and 3.7.18-3) may be stored in Region 2.

• There are no restrictions on enrichment/burnup/cooling time on fuel assemblies stored in Region 2 if the assembly contains a full length RCCA.

However, if the enrichment, burnup, and cooling time of a fuel assembly stored in Region 2 is NOT in the "Acceptable" domain in Figure 3.7.18-2 or 3.7.18-3 (e.g., the assembly requires a full length RCCA for storage in Region 2), then the assembly must be in a Region 1 storage location when its RCCA is inserted or removed.

These requirements ensure the following:

• Under normal operating conditions kett will remain ~ 0.95 with 900 ppm of soluble boron in the SFP, and will remain< 1.0 with 0 ppm of soluble boron in the SFP.

• Under all postulated accident scenarios kett will remain ~ 0.95 with 2600 ppm of soluble boron in the SFP.

o TS 3.7.17 requires a minimum of 2600 ppm of boron in the SFP whenever fuel is stored in the SFP. This requirement will not be changed.

SR 3.7.18.1 Surveillance Requirement (SR) 3. 7.18.1 is updated to instruct personnel to confirm that initial enrichment, burnup, cooling time, RCCA placement, and location of assemblies are acceptable.

TS Figure 3.7-18-1 TS Figure 3.7.18-1 is replaced. The new figure shows a typical Region 1 checkerboard arrangement.

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Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 7 of 26 TS Figure 3.7.18-2 and Figure 3.7.18-3 TS. Figure 3.7.18-2 is replaced by two figures. These new figures show the minimum required fuel assembly burnup and cooling time as a function of initial enrichment to permit storage in Region 2. Note that any fuel assembly containing a full length RCCA can be stored in Region 2 regardless of its initial enrichment/burnup/cooling time combination.

2.2 TS 4.3 - Fuel Pool Storage The proposed change to TS 4.3.1 will increase the licensed maximum U-235 enrichment to 5.0 weight percent and include an allowance for biases in the Keff calculations. The proposed change will also increase the boron concentration for Keff ~ 0.95 if fully flooded with borated water from 350 ppm to 900 ppm, The proposed changes follow:

TS 4.3.1 - Criticality TS 4.3.1.1 is updated to increase the maximum U-235 enrichment from 4.6 weight percent to 5.0 weight percent for fuel assemblies stored in the SFP and include an allowance for biases in the Keff calculations. Also, for Keff ~ 0.95 if fully flooded with borated water, the boron concentration is increased to 900 ppm.

TS 4.3.1.2 is updated to increase the maximum U-235 enrichment from 4.6 weight percent to 5~0 weight percent for fuel assemblies stored in the NFSR and include an allowance for biases in the Keff calculations.

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 8 of 26 3.0

• Discussion 3.1 Introduction Dominion proposes to amend Operating Licenses NPF-4 and NPF-7 by incorporating the attached proposed changes into the NAPS TS. A description of the proposed change is provided in Section 1.0 above. The supporting Criticality Safety Evaluation Report is included as Attachment 6 (Proprietary) and Attachment 7 (Non-proprietary).

The criticality safety evaluation supports the increase in the fuel assembly maximum U-235 enrichment to 5.0 weight percent.

Two unique Regions have been analyzed for the SFP. A Region is a particular geometric arrangement of fuel assemblies and empty storage locations. Region 1 features 2-out-of-4 storage with fuel assemblies in a checkerboard arrangement, and Region 2 features 4-out-of-4 storage (no empty storage locations). There are 6 unique rack sizes in the NAPS SFP. All of the racks have the same storage cell design (flux trap Boraflex racks) and nominal fuel assembly pitch. No credit is taken for Boraflex, which the criticality safety evaluation models as water. The rack design and the modeling of the racks in the SCALE code are discussed in the criticality safety evaluation.

There are 1737 storage locations in the NAPS SFP as follows:

• Three 9x9 racks

• One 9x12 rack

• Four 1Ox11 racks

• One "special" 1Ox11 rack (5 storage locations displaced by two failed fuel assembly storage locations)

• Six 1Ox12 racks

• One 11x11 rack The criticality safety evaluation was performed for each Region independently.

The results verified that no adverse boundary effects occur at Region interfaces.

The analysis includes soluble boron credit for both Regions in addition to burnup and cooling time credit for Region 2 (for those Region 2 fuel assemblies not containing a full length RCCA). The present TS SFP boron concentration requirement of 2600 ppm will not change.

The proposed amendment implements the following conditions associated with fuel assembly storage at NAPS:

• Increases the licensed fuel assembly maximum U-235 enrichment from 4.6 weight percent to 5.0 weight percent.

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 9 of 26

• Revises the allowed storage patterns and initial enrichmenUburnup/cooling time for fuel assemblies in the SFP to meet keff requirements under normal and accident conditions as follows:

o New Region 1 will require that fuel assemblies be stored in a checkerboard arrangement (2-out-of-4 storage) but will have no burnup curve.

o New Region 2 will have two new burnup curves, and all Region 2 storage locations will be available for fuel assembly storage. The new burnup requirements will also incorporate cooling time for determining whether a fuel assembly is permitted to be stored in Region 2.

• Permits the storage of any fuel assembly containing a full length RCCA in Region 2 without regard to the new burnup curves.

3.2 Current North Anna Spent Fuel Pool Configuration The NAPS SFP is not currently regionalized. However, fuel assembly storage must conform to the current fuel assembly burnup curve and matrix storage configuration. An assembly's initial enrichmenUburnup determines whether it can be stored in a non-matrix or low reactivity matrix location, or must be stored in a high reactivity matrix location.

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Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 10 of 26 4.0 Technical Evaluation Summary

4. 1 Introduction The analysis and results in this section are summarized from the Criticality Safety Evaluation Report (Attachment 6 {Proprietary} I Attachment 7 {Non-proprietary}):

The topics presented herein had the most significant impact with regard to the proposed license amendment.

The proposed license amendment does not result in any equipment modifications to the plant or any changes regarding how equipment is operated and maintained.

There are no changes in how fuel assemblies are handled and moved, nor are

• there any changes in how they are inserted into or removed from a SFP or NFSR storage location. There is no change to how personnel qualify and verify fuel assembly storage in either the SFP or the NFSR. There are no changes to how RCCAs are inserted into or removed from fuel assemblies.

Note that there are two SFP Regions proposed with updated burnup curves *. one of which includes cooling time credit used for Region 2 storage, and a new checkerboard storage configuration used for Region 1 storage. However, the administrative process for verifying proper fuel assembly loading using the new checkerboard storage arrangement and new burnup curves will be the same as the process used for the present burnup curve and matrix storage configuration.

Also, the plant response to a fuel assembly misleading event remains the same.

From an operational perspective, the proposed license amendment is transparent.

SFP soluble boron concentration requirements will not change. The proposed change takes a partial reactivity credit for the soluble boron currently in place for postulated accident scenarios. The changes to the permissible storage configuration lead to the proposed TS Figure 3. 7 .18-1 for Region 1. The change in enrichment/burnup/cooling time values lead to the proposed TS Figures 3. 7 .18-2 and 3.7.18-3 for Region 2. However, there are no changes regarding how fuel assemblies are handled and moved, how RCCAs are inserted into and removed from a fuel assembly, or in the administrative means used to ensure that fuel assemblies are not dropped or misloaded.

4.2 Fuel Storage Criticality Analysis - General Dominion performed the criticality safety evaluation to support the proposed license amendment.

For every normal operational and postulated accident scenario (both in the NFSR and the SFP) the criticality safety evaluation conservatively assumes that each fuel assembly is of a design that maximizes fuel reactivity. For the NFSR and Region 1 of the SFP, the limiting fuel assembly has the following characteristics:

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 11 of 26

• fresh (no burnup)

• enrichment of 5.0 weight percent U-235

• no credit taken for any integral fuel assembly burnable absorbers (which typically exist in fresh fuel assemblies)

• fuel design that bounds all presently stored and anticipated fuel assemblies For Region 2 of the SFP, the analysis assumes a bounding fuel assembly design and bounding conservative depletion conditions. The NFSR and SFP analyses account for the biases and uncertainties described in the criticality safety evaluation.

4.3 New Fuel Storage Racks Criticality Analysis - Normal Storage and Accident Conditions Results of the criticality safety evaluation showed that the NFSR maintains kett ~

0.95 under normal storage conditions, accounting for biases and uncertainties.

The following postulated accident conditions were analyzed:

• NFSR area fully flooded (with water)

• NFSR area with optimum moderation (fully flooded with foam).

The results also showed that the SFP maintains kett ~ 0.95 for the area fully flooded scenario, and maintains kett < 0.98 with optimum moderation.

4.4 Spent Fuel Pool Criticality Safety Evaluation - Normal Storage Conditions Results of the SFP criticality safety evaluation showed that the proposed SFP storage configuration will maintain kett <1.0 with 0 ppm of soluble boron in the SFP water, and kett ~ 0.95 with the SFP filled with 2600 ppm soluble boron for normal fuel assembly storage conditions.

In order to remain bounded by the criticality safety evaluation, Region 1 locations in the SFP must meet these requirements:

• fuel assemblies be stored in a 2-out-of-4 configuration as shown in proposed TS Figure 3.7.18-1

• each Region 1 storage block must have empty storage locations at the outer corners

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 12 of 26

• a Region 1 storage block cannot cross a spent fuel rack boundary where a rack module is adjacent to another rack module (this requirement eliminates the need to perform a rack-to-rack misalignment analysis):

o rack modules that are adjacent to the SFP wall may credit the wall region as empty cells for the purposes of meeting the Region 1 requirements of proposed LCO 3.7.18.a.ll.i and 3.7.18.a.11.iii since the reactivity of the wall region is bounded by the Region 1 checkerboard storage arrangement.

• there must be at least 2 rows of Region 2 rack storage locations between Region 1 storage blocks.

• a Region 1 block must not include SFP storage locations AA21, AA22, 8821, 8822, CC21, and CC22.

Storage in Region 2 requires that:

• fuel assemblies that do not contain an RCCA meet the initial enrichmenUburnup requirements in proposed TS Figure 3.7.18-2 or the enrichmenUburnup/cooling time requirements in TS Figure 3.7.18-3 o fuel assemblies containing a full length RCCA are not required to meet the enrichmenUburnup/cooling time requirements.

Results of the SFP criticality safety evaluation showed that, for both SFP Regions, 900 ppm of soluble boron under normal conditions assures that the SFP maintains kett .:5. 0.95 (including biases and uncertainties). Also, even with 0 ppm of soluble boron, under normal conditions the SFP was demonstrated to maintain kett < 1.00 (including biases and uncertainties). However, the present requirement to maintain 2600 ppm in the SFP (TS 3.7.17) is not being changed.

4.5 Spent Fuel Pool Criticality Safety Evaluation - Accident Conditions The SFP criticality safety evaluation has analyzed the following postulated accident conditions. Credit for soluble boron is acceptable for these accident conditions per the double contingency principle. In each case the criticality safety evaluation includes all biases and uncertainties:

• Multiple mislead of fresh 5.0 weight percent U-235 fuel assemblies in each spent fuel storage location (both Regions).

• Drop of a fresh 5.0 weight percent U-235 fuel assembly on top of a fuel assembly storage rack which leads to fuel assembly crushing.

• Mislead or drop of a fresh 5.0 weight percent U-235 fuel assembly outside of the fuel racks.

• A temperature increase in the SFP due to loss of cooling.

• A fuel handling event that brings two fresh 5.0 weight percent U-235 fuel assemblies, not stored in a spent fuel rack or dry shielded container, less than 12 inches from each other.

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Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 13 of 26

• Seismic event.

The limiting accident is multiple mislead of fuel assemblies in each fuel storage location. The criticality safety evaluation shows that 2600 ppm of soluble boron maintains kett ~ 0.95 for this scenario.

The current TS, which will not be changed, require a minimum soluble boron concentration of 2600 ppm at all times that fuel is in the SFP.

4. 6 Boron Dilution The proposed change will not affect the SFP minimum soluble boron concentration requirement which will remain at 2600 ppm. No equipment that could contribute to a boron dilution event will be changed as part of this proposed license amendment.

Thus, no new avenues for a boron dilution event will be created. There are no proposed changes regarding boron concentration maintenance or response to a boron dilution event.

The existing boron dilution analysis assumes a boron dilution from 2300 ppm to 1200 ppm soluble boron but conservatively calculated that the SFP maintains kett ~

0.95 at 900 ppm. The criticality safety evaluation analyzed the same boron dilution event for the proposed change and determined that the SFP would continue to maintain kett ~ 0.95 at 900 ppm soluble boron.

4. 7 Storage of Non-fuel Components and Non-standard Fuel Assemblies The criticality safety evaluation found that non-fuel components may be placed in any spent fuel rack storage location where fuel assemblies are allowed since these components are less reactive than fuel. Non-fuel components can also be placed in the guide tubes of any fuel assembly because the fuel lattice is under moderated.

The criticality safety evaluation evaluated each existing Non-standard Fuel Assembly stored in the NAPS SFP using the same methods used for standard fuel.

The attached criticality safety evaluation (Chapter 12) provides a list of the Non-standard Fuel Assemblies and whether they require a RCCA for Region 2 storage to maintain kett ~ 0.95.

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 14of26 4.8 Spent Fuel Pool Storage - Other Items This section .discusses several other items relevant to the proposed license amendment.

Seismic Response:

The NAPS SFP is currently licensed to store a fuel assembly in each of the 1737 spent fuel rack storage locations (TS 4.3.3). Thus, the SFP seismic/structural loading requirements for the proposed change are bounded by the existing TS.

The criticality safety evaluation analyzed the reactivity impact of a postulated seismic event considering the increased fuel enrichment, and found that the spent fuel racks maintain ketr ~ 0.95. The evaluation considered fuel assembly and spent fuel rack motion during the event. The reactivity impact of the seismic event is bounded by the bounding postulated accident (multiple mislead of fresh 5.0 weight percent U-235 fuel assemblies in each spent fuel storage location).

NOTE: NAPS experienced a seismic event in 2011 that resulted in ground motion exceeding its Safe Shutdown/Design Basis Earthquake in part of the seismic spectrum. The NRC issued a Confirmatory Action Letter (CAL) listing 10 commitments that Dominion has since satisfactorily completed leading to closure of the CAL. Closure of the CAL signifies that the August 23, 2011 earthquake did not cause any damage to NAPS' systems, structures, and components (SSCs) or their anchorage. A seismic margin management plan (SMMP) was implemented as part of the response to the August 23, 2011 earthquake. The SMMP provides guidance for evaluating piping systems and supports and for the seismic qualification of new and replacement equipment. The SMMP provides additional assurance that NAPS SSCs can operate safely in the long-term.

Fuel Handling Event:

The criticality safety evaluation analyzed a postulated fuel handling event that brings two fresh 5.0 weight percent U-235 fuel assemblies, not stored in a spent fuel rack or dry shielded container, within 12 inches (30.48 cm) from each other.

The analysis shows that ketr is maintained~ 0.95 with 0 ppm of soluble boron in the SFP water for a distance ~ 12 inches. With credit for soluble boron the criticality safety evaluation shows that ketr is maintained ~ 0.95 for any distance less than 12 inches apart.

As part of the implementation of the proposed license amendment, a procedural constraint will be added to require that a fuel assembly being moved via the fuel building movable platform crane (FBMPC) must never be closer than 12 inches (30.48 cm) from any assembly that is not stored in a spent fuel rack or dry shielded container storage location. The only practical scenarios in which this event could occur would be if a fuel assembly is stored in either the upender or new fuel elevator while another assembly is being moved by the FBMPC.

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Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 15 of 26 Radiological Consequences of Accidents:

The radiological consequences of accident scenarios described in the North Anna UFSAR will not increase as a result of the proposed increase in fuel enrichment.

Assessments of the impact of increasing the fuel burnup by the NRC and fuel vendors demonstrated that radionuclide concentrations in the fuel are largely a function of fuel burnup and power rather than fuel enrichment (References 7, 8, and 9). North Anna Units 1 and 2 burnup (lead rod burnup of 60,000 MWD/MTU)

(Reference 6) and power limits (rated thermal power of 2940 MWt) (Reference 4) will not change as a result of the increase in maximum initial fuel enrichment.

Increasing initial fuel enrichment, while maintaining burnup and power, results in a decrease in* dose consequences. Thus, the proposed license amendment does not increase the radiological consequences of postulated accidents.

Safety Analysis Limits:

Other than the proposed changes to those TS which specify maximum U-235 enrichment and SFP positioning, there are no changes to any TS LCO or operating or safety-related setpoints associated with the proposed increase in the maximum U-235 enrichment. No changes are being made to the core power level, operating temperature or pressure, or any peaking factors. There will be no change to existing limits on the primary system coolant activity.

SFP Heat Load:

The proposed license amendment makes no changes to the core power level, operating temperature or pressure, or any peaking factors. The maximum allowable SFP heat load will remain the same, and future reload designs shall continue to meet the present maximum SFP heat load requirement.

Environmental Effects:

The environmental effects of higher enrichment fuel and SFP criticality calculation changes are analyzed in terms of the radiological impacts, concerning both normal and accident conditions. Radiological impacts are only indirectly affected by increasing fuel enrichment. The radiological impacts are primarily a function of operating power and burnup. Assemblies with higher enrichments could be utilized for an additional cycle of operation, but the power level will remain the same.

Therefore, increased fuel enrichments will result in the same power level but could increase burnups.

The environmental impact of operation of the North Anna units with high burnup fuel was previously addressed in References 3 through 6. Westinghouse has generically addressed the impact of extended burnup on the design and operation of Westinghouse fuel (Reference 7). In addition, the NRC had an independent assessment conducted (Reference 8 and 9) of the environmental and economic impacts of the use of extended burnup fuels in light water power reactors.

__J

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 16 of 26 The overall findings of these assessments were that no significant adverse effects would be generated by increasing the batch average burnup to values of 50,000 MWD/MTU or above as long as the maximum rod average burnup of any fuel rod is not greater than 60,000 MWD/MTU. These evaluations concerning the impact of extended burnup fuel are valid for an enrichment of 5.0 weight percent U-235. In 1993, the NRC approved operation of North Anna fuel to burnup levels consistent with these findings (References 5 and 6).

Increasing burnup has limited effect on the short-lived isotope inventory in the fuel due to the development of an equilibrium condition between production and decay.

Instead, extended burnups increase the fraction of the short-lived isotopes that migrate into the fuel-clad gap region (Reference 8). With increasing burnup there is no decrease in fuel rod integrity or the leakage probability of a fuel rod. However, with the increased activity in the clad-gap region, increased burnup can result in increased activity being released into the reactor coolant under normal operations.

The increase is small enough to be easily accommodated by the reactor coolant clean up system.

Finally, the proposed license amendment will not change the operating power or lead rod and other fuel burnup limits. Thus, it is concluded that the increase in the maximum fuel enrichment to 5.0 weight percent U-235 for NAPS Units 1 and 2 will not have a significant adverse environmental effect.

Fuel Rod Integrity:

Fuel rod integrity is also not directly affected by the initial fuel enrichment. Fuel rod integrity is more sensitive to operating power, radial peaking factors, and operating temperature of the cladding than to fuel enrichment or burnup. Extensive studies have been conducted that show that there is no loss in fuel integrity for fuel rod average burnups reaching and exceeding 60,000 MWD/MTU as long as the operating power remains normal (Reference 8).

The fuel melt temperature for unirradiated U02 is -5080°F. Although this property of U02 is not a function of enrichment, the fuel melt temperature decreases with burnup (Reference 7). The North Anna overpower limits are set to ensure no fuel melting occurs, and this is verified each cycle as part of the reload safety analysis.

The current generation North Anna fuel uses Optimized ZIRLO for fuel cladding, guide thimbles, instrumentation thimbles, and mixing vane grids. Optimized ZIRLO and ZIRLO replaced Zircaloy for the purpose of enhancing the reliability of the clad and extending fuel burnup levels. However, References 7 and 8 deal with fuel assemblies whose cladding is constructed from Zircaloy.

The Optimized ZIRLO alloy is similar to Zircaloy-4 in chemical composition, physical properties and chemical properties. The Optimized ZIRLO alloy has improved corrosion resistance and dimensional stability under irradiation.

Westinghouse has addressed the performance of the Optimized ZIRLO alloy in fuel assemblies in Reference 10. This assessment concludes that there is no

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 17 of 26 degradation in the performance of the Optimized ZIRLO alloy to a burnup beyond the current lead fuel rod burnup limits.

The NAPS operating power, radial peaking factors, operating temperatures, and maximum burnup limits will not be changed when the fuel enrichment is increased.

Therefore, it is concluded that the increase in the maximum fuel enrichment to 5.0 weight percent U-235 for NAPS Units 1 and 2 will not have a significant adverse effect on the integrity or performance of the fuel rods. These factors also indicate that the probability of leakage from the fuel rods under normal conditions will not be affected by the increased fuel enrichment.

Control Rod Insertion:

Concerns have been raised about the possible effects of fuel burnup on the fuel assembly structure, potentially leading to conditions that could interfere with control rod insertion and thus the safe shutdown of the reactor. It has been postulated that such conditions could develop at higher fuel burnups as a result of the mechanical design of the fuel assembly guide thimble tubes, the material used to fabricate the fuel assembly skeleton, and irradiation induced changes to the fuel assembly such as growth and corrosion. No changes to the TS SFP boron concentrations are proposed. Therefore, the fuel assembly storage environment will not significantly change.

The irradiation induced factors that could conceivably affect the guide thimble geometry and thus the ability to insert the control rods as designed are burnup, rather than enrichment, related. Use of a slightly higher initial U-235 enrichment, with no increase in the fuel burnup limits, will not adversely affect fuel performance in any way which would affect the ability of the control rods to fully insert.

NAPS continues to perform cycle specific calculations to verify that our core designs incorporate sufficient shutdown margin to ensure safe shutdown if the most reactive RCCA fails to fully insert. An increase in the initial fuel enrichment from 4.6 to 5.0 weight percent of U-235 will not affect the nature of such shutdown margin calculations for NAPS 1 and 2.

4.9 Implementation Considerations Following NRC approval of the proposed license amendment, Dominion will rearrange fuel assemblies in the SFP so that each fuel assembly will be in compliance with the new SFP storage arrangement and enrichment/burnup/cooling time curves.

Given the planning and effort needed to perform this campaign, and the uncertainties with projecting a schedule a year away, Dominion plans to complete this work and fully implement the revised TS within six (6) months after NRC approval of the proposed license amendment.

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 18 of 26 4.10 Conclusions Implementation of the proposed license amendment is safe and will have no effect on plant operation. The proposed change will make no modifications to equipment or how equipment is* operated or maintained. In particular, there are no changes to how fuel is handled, including how fuel is moved, inserted into, and removed from SFP and NFSR storage locations. There are no changes to qualifying and verifying fuel storage in the SFP. There are no changes to the required response to a fuel misloading or drop event. There are no changes to how RCCAs are handled, including how RCCAs are moved, inserted into or removed from a fuel assembly or other location.* Also, since the proposed license amendment does not modify plant equipment or its operation and maintenance, including equipment used to maintain SFP soluble boron levels, the proposed license amendment will not impact the boron dilution event or plant response to it.

SFP rack storage requirements will continue to be maintained by administrative means to assure compliance with the new checkerboard storage configuration for Region 1 and the new burnup curves for Region 2, and the allowance to store fuel containing an RCCA in Region 2 without consideration of the burnup curves. The consequences of, or plant response to, a fuel misload event are not chahged.

Fuel assemblies containing a full length RCCA that are stored in Region 2, for which the enrichment, burnup, and cooling time is NOT in the "Acceptable" burnup domain of the proposed burnup curves (e.g., the assembly requires a full length RCCA for storage in Region 2), must be in a Region 1 storage location when the RCCA is inserted or removed. This requirement will be met using Administrative controls that are consistent with other measures utilized to assure proper storage of fuel assemblies. If this requirement was ever not fulfilled, the plant response remains unchanged from other fuel assembly misloading errors.

The criticality safety evaluation shows that the NFSR will maintain keff ~ 0.95 in the fully flooded condition and < 0.98 in the optimum moderation condition. Further, the criticality safety evaluation shows that the SFP will maintain keff ~ 0.95 under normal and all postulated accident conditions with credit for soluble boron. The SFP will also maintain keff < 1.0 with no soluble boron under normal conditions.

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 19 of 26 5.0 Regulatory Evaluation

5. 1 Applicable Regulatory Requirements and Criteria Appendix A to Title 10 of the Code of Federal Regulations, Part 50 (10 CFR 50),

General Design Criterion (GDC) 62, "Prevention of criticality in fuel storage and handling," states that "criticality in the fuel storage and handling system shall be prevented by physical systems or processes, preferably by use of geometrically safe configurations." The NRC has established a 5% subcriticality margin (i.e., k-effective (kett) less than or equal to 0.95) for nuclear power plant licensees to comply with GDC 62.

10 CFR 50.68 subpart (b), regarding New Fuel Storage Racks, specifies that "(2)

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

(3) If optimum moderation of fresh fuel in the fresh fuel storage racks occurs when the racks are assumed to be loaded with fuel of the maximum fuel assembly reactivity and filled with low-density hydrogenous fluid, the k-effective corresponding to this optimum moderation must not exceed 0.98, at a 95 percent probability, 95 percent confidence level. This evaluation need not be performed if administrative controls and/or design features prevent such moderation or if fresh fuel storage racks are not used" Also, Subpart (b)(4) of 10 CFR 50.68, "Criticality acddent requirements," specifies, "if credit is taken for soluble boron, the k-effective of the SFP storage racks loaded with fuel of the maximum fuel assembly reactivity must not exceed 0.95, at a 95 percent probability, 95 percent confidence level, if flooded with borated water, and the k-effective must remain below 1.0 (subcritical), at a 95 percent probability, 95 percent confidence level, if flooded with unborated water."

5.2 No Significant Hazards Consideration Dominion has performed the significant hazards consideration for the proposed license amendment by addressing 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.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 20 of 26 Response: No.

The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change will not affect the plant equipment or structure, including the SFP, NFSR, or fuel handling equipment, including how equipment is operated and maintained. There are no changes to the equipment for fuel handling or how fuel assemblies are handled, including how fuel assemblies are inserted into and removed from SFP and NFSR storage locations. There will be no changes to administrative means to verify correct fuel assembly storage in the SFP, which will now also be used to verify required RCCA storage in selected Region 2 assemblies, or the required response to a fuel assembly misleading or drop event. There are no changes to how RCCAs will be handled, including how RCCAs are inserted into or removed from a fuel assembly or other location such as a SFP storage location. Also, since the proposed change does not modify plant equipment or its operation and maintenance, including equipment used to maintain SFP soluble boron levels, the proposed change will not impact a boron dilution event or plant response to it.

The criticality safety evaluation concluded that the NFSR limiting accident is the optimum moderation condition with each storage location loaded with a maximum reactivity fuel assembly. The NFSR will maintain kett <

0.98 for this postulated scenario including all uncertainties and biases.

The NFSR also maintains kett ~ 0.95 for the fully flooded scenario including all uncertainties and biases. Thus, the consequences of an accident previously evaluated regarding the NFSR is not significantly increased. There is no change to the plant equipment or its operation and maintenance due to the proposed change. Thus, the probability of a flooding accident that could impact the NFSR is not significantly increased.

Regarding the SFP, there will now be.two storage Regions. The process of choosing fuel assembly storage locations will not change, except that the storage arrangement (checkerboard) and burnup requirements will be revised and assemblies containing an RCCA can be stored in Region 2 without consideration of the burnup curves. The physical handling, insertion, removal, and storage of fuel assemblies in SFP racks will not change. The NAPS program for choosing fuel assembly storage locations, for fuel handling, and for assuring that the fuel assemblies are placed into correct locations will remain in place. Thus, the probability of a fuel assembly misleading or a fuel assembly drop in the SFP will not significantly increase due to the proposed change.

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 21 of 26 A number of postulated accidents for the SFP were reviewed for the proposed change which included postulated fuel assembly misloading and drop scenarios. The criticality safety evaluation for the SFP concluded that the limiting accident, which bounds all other scenarios, is a multiple misload of a maximum reactivity fuel assembly into each SFP storage location. The criticality safety evaluation concluded that a SFP soluble boron concentration of 2600 ppm will maintain kett ~ 0.95 including all uncertainties and biases for this postulated scenario. The current TS, which is not being changed, requires a minimum concentration of 2600 ppm soluble boron at all times that fuel is in the SFP. Since there is no change to the plant equipment that maintains boron concentration or how the boron concentration is maintained, the probability of an accident involving an incorrect amount of SFP soluble boron is not significantly increased. Also, since kett would remain ~ 0.95, there is no significant increase in the consequences of a postulated accident.

There are no changes to plant equipment, including its operation and maintenance, as a result of the proposed change, including equipment associated with maintaining SFP soluble boron concentration or possible flow paths that could contribute to a boron dilution event. Thus, no new avenues for a boron dilution event will be created. There will be no change regarding how the plant maintains boron concentration or responds to a boron dilution event. The criticality safety evaluation for the postulated boron dilution event shows that, like the existing analysis, the SFP maintains kett ~ 0.95 at 900 ppm soluble boron. Thus, there is no significant increase in the probability or consequences of a boron dilution accident.

In each of the above scenarios the proposed change does not significantly increase the probability of an accident previously evaluated. In each postulated accident kett continues to be less than or equal to the licensing limit of 0.95, or less than 0.98 for the NFSR optimum moderation scenario.

The NAPS SFP is currently licensed to store a fuel assembly in each of the 1737 spent fuel rack storage locations. Thus, the SFP seismic/structural loading requirements for the proposed change are bounded by the existing TS which have been shown to protect the fuel during normal and accident conditions, including during a postulated seismic event. Thus, there is no increase in the consequences of a seismic event.

The proposed license amendment makes no changes to any safety analysis limits, including core power level, operating temperature or pressure, or peaking factors. There are no changes being made to any fuel burnup limits. Thus, it is concluded that;

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 22 of 26

• there is no increase in the radiological consequences in response to postulated accidents

• there is no change to the maximum allowable SFP heat load

• there is no impact on fuel rod integrity during normal or accident conditions

• there is no impact on the ability of RCCAs to fully insert during normal or accident conditions.

Thus, it is concluded that the probability or consequences of a previously evaluated accident do not significantly increase.

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

Response: No.

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

There is no change to any plant equipment, including how equipment is operated and maintained. Equipment used to handle fuel assemblies (or any heavy load) over the NFSR or the SFP, or how the fuel assemblies are stored, inserted into and removed from fuel storage locations is not changed. There is no change to how RCCAs will be inserted into or removed from a fuel assembly or other location, or otherwise how RCCAs are handled. Any fuel assemblies containing a RCCA may now be stored in Region 2 without being in the "Acceptable" region of the burnup curves.

However, if such an assembly was stored in Region 2 without the RCCA, it would be treated as any other fuel mislead event in which an assembly is stored in Region 2 without meeting the requirements of the burnup curves. Thus, there are no new accidents created over and above the existing postulated accidents of a fuel mislead or a fuel assembly drop in the SFP, or a flooding event in the NFSR area.

Also, since there is no change to the plant equipment or how equipment is operated and maintained, the probability of a new type of accident that could impact the SFP or NFSR is not significantly increased~

Since the proposed change will not change fuel/RCCA handling equipment or how fuel assemblies and RCCAs are handled and stored, nor will it change any other plant equipment, there is no mechanism for creating a new or different kind of accident not previously evaluated.

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

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 23 of 26

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

Response: No.

The proposed change does not involve a significant reduction in a margin of safety The licensing requirement for the SFP is that keff remain ~ 0.95 under normal and all postulated accident conditions with credit for soluble boron.

The criticality safety evaluation concluded that this requirement is met for the bounding postulated accident of a multiple mislead of a maximum reactivity fuel assembly into each SFP storage location, and for the postulated boron dilution event.

In addition the criticality safety evaluation concluded the following regarding normal conditions with 0 ppm soluble boron in the SFP:

• The SFP will maintain keff < 1.0.

• For a fuel handling event that brings two fresh 5.0 weight percent U-235 fuel assemblies, not stored in a spent fuel rack or dry shielded container, within 12 inches (30.48 cm) from each other, keff is maintained < 0.95 with 0 ppm of soluble boron in the SFP water for a distance > 12 inches. With credit for soluble boron keff is maintained < 0.95 for any distance less than 12 inches apart.

The criticality safety evaluation also allows the following storage configurations. In each case the storage configuration either reduces or does not increase reactivity assuring that keff margin is maintained:

• Storing a RCCA and/or cell blocker in a Region 1 empty location

• Storing non-fuel components in any spent fuel rack storage location where fuel assemblies are allowed

• Storing non-fuel components in the guide tubes of any *fuel assembly.

The criticality safety evaluation evaluated Non-standard Fuel Assemblies stored in the NAPS SFP to determine whether they need to contain a RCCA for Region 2 storage. This information is used to maintain keff margin when storing Non-standard Fuel Assemblies.

The licensing requirements for the NFSR is that keff remain ~ 0.95 for the fully flooded scenario, and < 0.98 for the optimum moderation scenario.

The criticality safety evaluation concluded that these requirements are met assuming each storage location is loaded with a maximum reactivity fuel assembly.

Thus, all the margins of safety are maintained, and the proposed change does not involve a significant reduction in a margin of safety

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 24 of 26 Based on the above information, Dominion concludes that the proposed license amendment involves 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 changes to the NAPS technical specifications are similar in fundamental aspects to those referenced in this NRC Safety Evaluation Report:

1. NRC License Amendment and associated SER under cover letter "Millstone Power Station, Unit No. 2 - Issuance of Amendment Re: Technical Specification Changes for Spent Fuel Storage (TAC NO. MF0435)," from R. V. Guzman (NRC) to D. A. Heacock (Dominion), June 23, 2016.

The current NAPS application includes unique aspects that reflect Dominion's understanding of NRC staff expectations for the content and supporting analyses of spent fuel criticality submittals. The enclosed submittal content was developed based on insights and discussion between Dominion and NRC staff which occurred during a pre-submittal meeting:

1. Summary of April 26, 2016, Pre-Application Teleconference with Virginia Electric and Power Company for Increase in Maximum Fuel Enrichment for New Fuel Storage Racks and Spent Fuel Pool (CAC Nos. MF7432 and MF7433).

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 proposed changes, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the requested license amendments will not be inimical to the common defense and security or to the health and safety of the public.

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 25 of 26 6.0 Environmental Considerations Dominion 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.16-383 Docket Nos.: 50-338/339 Attachment 1 Discussion of Change Page 26 of 26 7 .0 References

1. NRG Interim Staff Guidance DSS-ISG-2010-01, Revision 0, "Staff Guidance Regarding the Nuclear Criticality Safety Analysis for Spent Nuclear Fuel Pools",

9/29/2011.

2. NUREG/CR-6801, "Recommendations for Addressing Axial Burnup in PWR Burnup Credit Analyses", ORNL!TM-2001/273, March 2003.

3. Letter from W. R. Cartwright (Virginia Electric and Power Company) to U.S.

Nuclear Regulatory Commission, "North Anna Power Station Units No. I and 2, Proposed Technical Specification Change, Fuel Enrichment Increase", Serial Number 88-603, September 30, 1988.

4. Letter from J. Alan Price (Virginia Electric and Power Company, Dominion) to the U.S. Nuclear Regulatory Commission, "North Anna Power Station Units 1 and 2 License Amendment Request Measurement Uncertainty Recapture Power Uprate", March 26, 2009.

5. Letter from Leon B. Engle and Bart C. Buckley (U.S. Nuclear Regulatory Commission) to W. L. Stewart (Virginia Electric and Power), "Surry, Units I and 2, and North Anna, Units 1 and 2 - Removal of 45,000 MWD/MTU Batch Average Burnup Restriction", December 14, 1993.

6. Letter from Leon B. Engle and Bart C. Buckley (U.S. Nuclear Regulatory Commission) to W. L. Stewart (Virginia Electric and Power), "Surry, Units I and 2, and North Anna, Units 1 and 2 - Removal of 45,000 MWD/MTU Batch Average Burnup Restriction", April 20, 1994.

7. S. L. Davidson and W. L. Kramer, Editors, "Extended Burnup Evaluation of Westinghouse Fuel", WCAP-10125-P-A (Proprietary), December 1985.

8. D. A. Baker, et al., "Assessment of the Use of Extended Burnup Fuel in Light Water Power Reactors", NUREG/CR-5009, PNL-6258, February 1988.

9. J. V. Ramsdell Jr., et al., "Environmental Effects of Extending Fuel Burnup above 60 Gwd/MTU", NUREG/CR 6703, PNNL-13257, January 2001.

10.Addendum 1 to WCAP-12610-P-A, "Addendum 1 to WCAP-14342-P-A and CENPD-404-P-A Optimized ZIRLO", February 2003.

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 2 MARKED-UP TECHNICAL SPECIFICATION PAGES VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1AND2

- NUCLEAR DESIGN INFORMATION PORTAL-Spent Fuel Pool Storage

3. 7 .18

3. 7 PLANT SYSTEMS and cooling time 3.7.18 Spent Fuel Pool Storage ~

LCO 3.7.18 The combination of initial enrichment~burnup assembly stored in the fuel storage pool shall be in of each fuel accordance with the following:

a. ew or irradiated fuel assemblies with a combination o bu up and initial nominal enrichment in the "Accept e" llnsert # 1 on next 1---->~ burn domain of Figure 3.7.18-1 may be stored in e fuel page storag ool in a non-matrix location or a low activity location

• the 5 x 5 matrix configuration sh n in Figure 3.7. -2. They may also be placed i a high reactivity lo tion if stored in the 5 x matrix configurations~ n in Figure 3.7.18-

b. New or irradiated fu of

c. New or irradi d fuel assemblies with of burnup and

• itial nominal enrichment in e "Unaccept le" domain of Figure 3.7.18-1 mus be stored in the fu storage pool in a high reactivity loc ion in the 5 x matrix configuration shown in Figure 3.7. -2. A fu assembly transferred from Surry for storage i the orth Anna fuel storage pool must be treated as a fu assembly in the "Unacceptable" domain.

APPLICABILITY: Whenever any fuel assembly is stored in the spent fuel pool.

North Anna Units 1 and 2 3. 7 .18-1 Amendments 231/212 J

Insert# 1 to TS 3.7.18 LCO:

a. Region 1 Fuel Storage Locations:

I. Fuel assemblies stored in Region 1 shall be stored in a 2-out-of-4 checkerboard arrangement with empty cells per Figure 3. 7 .18-1:

i. Empty cells shall remain empty with the exception of a Rod Cluster Control Assembly (RCCA) and/or a cell blocker.

II. A Region 1 checkerboard is a rectangle of assemblies that can be placed anywhere in the spent fuel pool with the following restrictions: 1

i. All 4 corners of a Region 1 block shall be an empty cell location.

ii. There shall be a minimum of two (2) Region 2 rows between two Region 1 blocks.

iii. Region 1 shall NOT cross a spent fuel rack module boundary.

iv. Spent Fuel Pool Locations AA21, AA22, 8821, 8822, CC21, and CC22 shall NOT be contained in a Region 1 block.

Ill. There are no restrictions on burnup and cooling time on fuel of initial enrichment of less than or equal to 5.0 weight percent (wt%) U-235.

b. Region 2 Fuel Storage Locations:

I. Irradiated fuel assemblies with a combination of initial enrichment and burnup in the "Acceptable" burnup domain in Figure 3.7.18-2 may be stored in Region 2.

II. Irradiated fuel assemblies cooled three (3) or more years with a combination of enrichment and burnup in the "Acceptable" burnup domain in Figure 3.7.18-3 may be stored in Region 2.

---

NOTE--------------------------------------------------------------

Regarding fuel assemblies that contain a full length RCCA - if the enrichment, burnup, and cooling time of such an assembly stored in Region 2 is NOT in the "Acceptable" burn up domain in Figure 3.7.18-2 or 3.7.18-3 (e.g., the assembly requires a full length RCCA for storage in Region 2), then the assembly must be in a Region 1 storage location when its RCCA is inserted or removed.

Ill. There are no restrictions on initial enrichment, burnup, and cooling time on a fuel assembly stored in Region 2 if the assembly contains a full length RCCA.

1 Rack modules that are adjacent to the spent fuel pool wall may credit the wall region as empty cells for the purposes of meeting the Region 1 requirements of LCO 3.7.18.a.ll.i and 3.7.18.a.ll.iii.

- NUCLEAR DESIGN INFORMATION PORTAL -

Spent Fuel Pool Storage

3. 7 .18 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the A.1 --------NOTE---------

LCO not met. LCO 3.0.3 is not applicable.

Initiate action to Immediately move the noncomplying fuel assembly to an acceptable location.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3. 7 .18 .1 'O'erify by a combrnat1on of visual Prior to storing i11spectior1 a11d ad111i11istrative 111ea11s Lliat the fuel the iAitial eArichmeRt, burRup aRd ~to1age assembly in the locatio11 of the a:s:sembly is acceptable. spent fuel pool Verify by a combination of visual inspection and administrative means that the initial enrichment, burnup, cooling time, RCCA placement, and location of the assembly are acceptable.

North Anna Units 1 and 2 3. 7 .18-2 Amendments 231/212 /

- NUCLEAR DESIGN INFORMATION PORTAL -

Spent Fuel Pool Storage 3.7.18 Replace with new Region 2 burnup curves.

5' I-

~

!!!. 25000-t-~~-+-~~-+......,,~-1r--~~#-~~T1--~~-+~~'--1r--~---t Cl.

I c

I al

~

~ 20000-t-~~-+-~~-+~~-11f-'"<-~f'-~~-+-~----+~~-1r--~---t Cl) en en

<(

Cii

I u..

Unacceptable 2.2 2.6 3 3.4 3.8 4.2 Initial U-235 Enrichment (nominal w/o)

Acceptable: cceptable for storage in non-matrix location or low reactivity location in configurati . May also be placed in high reactivity locations in matrix configuration.

ally Acceptable: Acceptable for storage in non-matrix location, but must be place in hig reactivity location if stored in matrix configuration.

Un ceptable: Must be stored in high reactivity location in matrix configuration. Surry spent f 1 must be stored in high reactivity locations in a matrix.

Figure 3.7.18-1 (page 1 of 1)

Burnup Credit Requirements North Anna Units 1 and 2 ' 3. 7 .18-3 Amendments 231/212

-NUCLEAR DESIGN INFORMATION PORTAL-Replace with new Region 1 Checkerboard Spent Fuel Pool Storage Arrangement (next page). 3. 7 .18 Low reactivity fuel

• (Per Figure 3.7.18 High reactivi (Per Figure .7.18-1, reactivity up to and 1 eluding 4.6 w/o U 235 fresh fuel cell containing no fuel assembl D

Notes to Figure:

1. at the boundary of the spent fuel pool storage locations is an

2. Storage o non-fueled components within the matrix or non-matrix cells that result reduced pent fuel pool keff is acceptable.

3. A sto age cell containing no fuel assembly may be substituted for any location in either ma ix or non-matrix configuration.

4. ent fuel transferred from Surry must be stored in high reactivity locations.

Figure 3.7.18-2 (page 1 of 1) 5 x 5 Matrix Storage Configuration North Anna Units 1 and 2 3.7.18-4 Amendments 231/212

Figure 3.7.18-1 (page 1 of 1)

Typical Region 1 Checkerboard

Equation for Curve:

40000 .............!..... Burnup=372.lx 3-5304.4x 2+36688x-53110

• • • • • • • • !***** where x is enrichment

~:i= I 35000 5"

~ 30000

ii:

~

c.

s E 25000

s

"':s Qi IL gi. 20000 E

GJ

~

~ 15000 GJ

~

10000 5000 0

1.5 2 2.5 3 3.5 4 4.5 Maximum Planar Average Enrichment (wt% U-235)

Figure 3.7.18-2: Minimum Burnup Requirements for Region 2 With No Credit for Cooling

45000 t---+-+-.,.-+--1--;--;---+--+--+--+--+- Equation for Curve:

40000 +--+---+---+--+--+--+--'--+---+---+--+---+- Burnup=404.2x3 -SS38 .2x2+36520x-52167 35000 S'

I-ACCEPTABLE AFTER 130000

~

c.

"E 25000 Qi u."

ilJ, 20000

<(

~

"E., 15000

~

10000 5000 0

1.5 2 2.5 3 3.5 4 4.5 Maximum Planar Average Enrichment (wt% U-235)

Figure 3.7.18-3: Minimum Burnup Requirements for Region 2 for Assemblies Cooled 3 Years or More

- NUCLEAR DESIGN INFORMATION PORTAL-Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site Location The North Anna Power Station is located in the north-central portion of Virginia in Louisa County and is approximately 40 miles north-northwest of Richmond, 36 miles east of Charlottesville; 22 miles southwest of Fredericksburg; and 70 miles southwest of Washington, D.C. The site is on a peninsula on the southern shore of Lake Anna at the end of State Route 700.

4.2 Reactor Core 4.2.1 Fuel Assemblies The reactor shall contain 157 fuel assemblies. Each assembly shall consist of a matrix of Zircaloy, ZIRLO, Optimized ZIRLO, or ~

M5 fuel rods with an initial composition of natural or slightly /'I enriched uranium dioxide (U0 2) as fuel material. Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with 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 locations.

4.2.2 Control Rod Assemblies The reactor core shall contain 48 control rod assemblies. The control material shall be silver indium cadmium, as approved by the NRC.

4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum U-235 enrichment of

/...../Jr.fr weight percent; 5.0 North Anna Units 1 and 2 4.0-1 Amendments 263/z44 \

- NUCLEAR DESIGN INFORMATION PORTAL-Design Features 4.0 4.0 DESIGN FEATURES 4.3.1.1 (continued)

b. keff < 1.0 if fully flooded with unborated wate_r,__....-and biases; which includes an allowance for uncertainties~

calcHlated iR ~CCQrd~RCe witb tbe methodology de~e1 ibed i11 'Ji 1gi11ia Elect1 ic a11d Power Crn11pa11y letter dated SeptembeF 27, 2000 (Sefial Ne. 00 491),

and biases;

c. keff ~ 0.95 if tully flooded with water borated to 900----:>'j/"-3-W-ppm, whic~!ncludes an allowance for uncertainties GalcHlate~ iR accefdaRee with the metbadalagy described iR VirgiRia ~lectFic aRd Pewer CgmpaRy letter dated September 27, 2000 (SeFial Nu.00-491), and

d. A nominal 10 9/16 inch center to center distance between fuel assemblies placed in the fuel storage racks.

• 4.3.1.2 The new fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum U-235 enrichment of

~-4-:-6-weight percent; 5.0

b. keff ~ 0.95 if fully flooded with unborated water, which includes an allowance for uncertain~;

and biases - - - - '

c. keff ~ 0.98 if moderated by aqueo~o~m, which includes an allowance for uncertai"'nt~; and

d. A nominal 21 inch center to center distance between fuel assemblies placed in the storage racks.

4.3.2 Drainage The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 285 feet, 9 inches, Mean Sea Level, USGS datum.

4.3.3 Capacity The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than 1737 fuel assemblies.

North Anna Units 1 and 2 4.0-2 Amendments 231/212 \

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 3 PROPOSED TECHNICAL SPECIFICATION PAGES VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2

Spent Fuel Pool Storage 3.7.18 3.7 PLANT SYSTEMS 3.7.18 Spent Fuel Pool Storage LCO 3.7.18 The combination of initial enrichment, burnup and cooling time of each fuel assembly stored in the fuel storage pool shall be in accordance with the following:

a. Region 1 Fuel Storage Locations:

I. Fuel assemblies stored in Region 1 shall be stored in a 2-out-of-4 checkerboard arrangement with empty cells per Figure 3.7.18-1:

i. Empty cells shall remain empty with the exception of a Rod Cluster Control Assembly (RCCA) and/or a cell blocker.

II. A Region 1 checkerboard is a rettangle of assemblies that can be placed anywhere in the spent fuel pool with the following restrictions:*1

i. All 4 corners of a Region 1 block shall be an empty cell location.

ii. There shall be a minimum of two (2) Region 2 rows between two Region 1 blocks.

iii. Region 1 shall NOT cross a spent *fuel rack module boundary.

iv. Spent Fuel Pool Locations AA21, AA22, BB21, BB22, CC21, and CC22 shall NOT be contained in a Region 1 block.

III. There are no restrictions on burnup and cooling time on fuel of initial enrichment of less than or equal to 5.0 weight percent (wt%) U-235

b. Region 2 Fuel Storage Locations:

I. Irradiated fuel assemblies with a combination of initial enrichment and burnup in the 11 Acceptable 11 burnup domain in Figure 3.7.18-2 may be stored in Region 2.

II. Irradiated fuel assemblies cooled three .(3) or more years with a combination of initial enrichment and burnup in the 11 Acceptable 11 burnup domain in Figure 3.7.18-3 may be stored in Region 2.

(continued)

1. Rack modules that are adjacent to the spent fuel pool wall may credit the wall region as empty cells for the purposes of meeting the Region 1 requirements of LCO 3.7.18.a.ll.i and 3.7.18.a.11.iii.

North Anna Units 1 and 2 3. 7 .18-1 Amendments

Spent Fuel Pool Storage 3.7.18

b. (continued)

- - - - - - - - - - - - NOTE - - - - - - - - - - - -

Regarding fuel assemblies that contain a full length RCCA -

if the enrichment, burnup, and cooling time of such an assembly stored in Region 2 is NOT in the "Acceptable" burnup domain in Figure 3.7.18-2 or 3.7.18-3 (e.g., the assembly requires a full length RCCA for storage in Region 2), then the assembly must be in a Region 1 storage location when its RCCA is inserted or removed.

III. There are no restrictions on initial enrichment, burnup, and cooling time on a fuel assembly stored in Region 2 if the assembly contains a full length RCCA.

APPLICABILITY: Whenever any fuel assembly is stored in the spent fuel pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the A.1 --------NOTE---------

LCO not met. LCO 3.0.3 is not applicable.

Initiate action to Immediately move the noncomplying fuel assembly to an acceptable location.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.18.1 Verify by a combination of visual Prior to storing inspection and administrative means that the fuel the initial enrichment, burnup, cooling assembly in the time, RCCA placement, and location of the spent fuel pool assembly are acceptable.

North Anna Units 1 and 2 3. 7 .18-2 Amendments

Spent Fuel Pool Storage 3.7 .18 Figure 3.7.18-1 (page 1 of 1)

Typical Region 1 Checkerboard North Anna Units 1 and 2 3. 7.18-3 Amendments

Spent Fuel Pool Storage

3. 7 .18 45000~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~-~~~

l*******'*********************************-l*****!******-r****+****+*************l***--+--i--i~l*--'f---f---i-J~

................... Equation for Curve:

=t..

....... .!... .. Burnup=372.lx 3 -5304.4x 2+36688x-53110 where x is enrichment 1

35000 --!--!--!--!---+---+---'-

~

~ 30000 +--+---~~

3

~

a.

E2sooo +-~__._

i Qi

~

~ 20000

~

~

e15000

~"

5000 1.5 2 2.5 3.5 4 4.5 Maximum Planar Average Enrichment (wt% U-235)

Figure 3.7.18-2 (page 1 of 1)

Minimum Burnup Requirements for Region 2 With No Credit for Cooling North Anna Units 1 and 2 3. 7 .18-4 Amendments

Spent Fuel Pool Storage 3.7.18

-~,

• • • • • • +*****+*****+*****+*******1*******+*****+****************>** Equation for Curve:

40000 --+--+--+--i-___.._---+-__,__,_ Burnup=404.2x 3-5538.2x 2+36520x-52167 where xis enrichment 10000 5000 0+--'---'---'--~+--'---'---'---'--+---'--

1.5 2.5 3.5 4 4.5 Maximum Planar Average Enrichment (wt% U-235) 1...................................................................................................**.*****...*................................................*.*******.**...*..........................................*.*........................................................ *****-******************-***********************************************!

Figure 3.7.18-3 (page 1 of 1)

Minimum Burnup Requirements for Region 2 for Assemblies Cooled 3 Years or More North Anna Units 1 and 2 3. 7 .18-5 Amendments

Intentionally Blank Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site Location The North Anna Power Station is located in the north-central portion of Virginia in Louisa County and is approximately 40 miles north-northwest of Richmond, 36 miles east of Charlottesville; 22 miles southwest of Fredericksburg; and 70 miles southwest of Washington, D.C. The site is on a peninsula on the southern shore of Lake Anna at the end of State Route 700.

4.2 Reactor Core 4.2.1 Fuel Assemblies The reactor shall contain 157 fuel* assemblies. Each assembly shall consist of a matrix of Zircaloy, ZIRLO, Optimized ZIRLO, or M5 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 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 locations.

4.2.2 Control Rod Assemblies The reactor core shall contain 48 control rod assemblies. The control material shall be silver indium cadmium, as approved by the NRC.

4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum U-235 enrichment of 5.0 weight percent; North Anna Units 1 and 2 4.0-1 Amendments

Design Features 4.0 4.0 DESIGN FEATURES 4.3.1.1 (continued)

b. keff < 1.0 if fully flooded with unborated water, which includes an allowance for uncertainties and biases;

c. keff ~ 0.95 if fully flooded with water borated to 900 ppm, which includes an allowance for uncertainties and biases; and

d. A nominal 10 9/16 inch center to center distance between fuel assemblies placed in the fuel storage racks.

4.3.1.2 The new fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum U-235 enrichment of 5.0 weight percent;

b. keff ~ 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties and biases;

c. keff ~ 0.98 if moderated by aqueous foam, which includes an allowance for uncertainties and biases; and

d. A nominal 21 inch center to center distance between fuel assemblies placed in the storage racks.

4.3.2 Drainage The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 285 feet, 9 inches, Mean Sea Level, USGS datum.

4.3.3 Capacity The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than 1737 fuel assemblies.

North Anna Units 1 and 2 4.0-2 Amendments

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 4 MARKED-UP AND PROPOSED TECHNICAL SPECIFICATION BASES PAGES (for information only)

VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1AND2

-NUCLEAR DESIGN INFORMATION PORTAL-Spent Fuel Pool Storage B 3.7.18 B 3.8 PLANT SYSTEMS B 3.7.18 Spent Fuel Pool Storage BASES BACKGROUND The fuel storage pool contains racks which hold the fuel assemblies. The arrangement of the fuel assemblies in the fuel racks can be used to limit the interaction of the fuel assemblies and the resulting reactivity of the fuel in the fuel storage pool. TRQ gQgm9trical arrang9m9nt is eased on elassifying f1:.1el assemalies as l9igl9 reactivity or low 11 11 11 reacti 11 ity based on the b11rn11p and i ni ti al enri cRm~r:it gf 11 tnsert#2 ~----:>'?' tAe f1:.1el assemalies. A§>(§ fl:.lel location FRatJCix is l_Next Page eFRpl eyed wi tl9 acceptaal e 1ocati OAS for 19i gl9 al'lel l O\J reactivity fuel assemblies. Fuel assemblies may also be stored in f1:.1el locations not associat9d witR a stgrag9 matrix if tt~e assemblies meet ce1tai1i 1eqtti1 e111e11ts.

Storing the fuel assemblies in the locations required by the LCO ensures a fuel storage pool keff < 1.0 for normal conditions. In addition, the water in the spent fuel storage pool contains soluble boron, which results in large subcriticality margins under normal operating conditions.

However, the NRC guidelines assume accident conditions, such as loss of all soluble boron or misleading of a fuel assembly. In these cases, the subcriticality margin is allowed to be smaller, but in all cases must be less than 1.0. This subcriticality margin is maintained by storing the fuel assemblies as described in the LCO and by the use of soluble boron in the fuel storage pool water as required by LCO 3.7.17, Fuel Storage Pool Boron Concentration. The 11 11 accident analyses assume the presence of soluble boron under accident conditions, such as the misleading of .a-fuel assemblies into ---->~ aS59m8ly into a locatiol'l not allowed by LCO 3.7.18, loss of locations cooling to the fuel storage pool resulting in ate erature increase of the fuel storage pool water, or a dilution of the boron dissolved in the fuel storage pool. a fuel assembly drop, A general description of the fuel storage pool design is given in the UFSAR, Section 9.1.2 (Ref. 1).

APPLICABLE Criticality of the fuel assemblies in the fuel storage pool SAFETY ANALYSES racks is prevented by the design of the rack and by administrative controls related to fuel storage pool boron concentration, fuel assembly burnup credit, and fuel storage (continued)

North Anna Units 1 and 2 B 3.7.18-1 Revision 0 I

~I_ _

--1 Insert# 2 for TSB 3.7.18

Background:

A Region 1 checkerboard arrangement is a rectangle of assemblies, referred to as a "block",

that can be placed anywhere in the fuel storage pool. The geometric arrangement for Region 1 is based on a 2-out-of-4 checkerboard arrangement, each corner of the Region 1 block being an empty location, and at least two (2) Region 2 rows between Region 1 blocks. A Region 1 block shall not cross a spent fuel rack boundary where a rack module is adjacent to another rack module. This requirement eliminates the need to perform a rack-to-rack misalignment analysis.

Rack modules that are adjacent to the spent fuel pool wall may credit the wall region as empty cells for the purposes of meeting the Region 1 requirements of LCO 3.7.18.a.ll.i and 3.7.18.a.ll.iii since the reactivity of the wall region is bounded by the Region 1 checkerboard storage arrangement. However, a Rod Cluster Control Assembly (RCCA) and/or cell blocker may be stored in an empty location because RCCAs are strong neutron absorbers and cell blockers are located above the fuel. There is no burnup curve for Region 1 storage Fuel assemblies may be stored in Region 2 if they are either in the acceptable burn up domain of the initial enrichment/burnup curve in Figure 3.7.18-2 or enrichment/burnup curve in Figure 3.7.18-3 for fuel assemblies with a cooling time of three (3) or more years (Cooling time is the time elapsed since the last use of a fuel assembly in a critical condition.). Any fuel assembly containing a full length RCCA, regardless of enrichment/burn up/cooling time may be stored in Region 2 because the RCCA provides enough negative reactivity to meet the kett requirements.

If the enrichment, burn up, and cooling time of a fuel assembly stored in Region 2 is NOT in the "Acceptable" burnup domain in Figure 3.7.18-2 or 3.7.18-3 (e.g., the assembly requires a full length RCCA for storage in Region 2), then the assembly must be in a Region 1 storage location when its RCCA is inserted or removed. This requirement prevents the assembly from becoming unqualified for Region 2 storage.

r-- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

- NUCLEAR DESIGN INFORMATION PORTAL-Spent Fuel Pool Storage B 3.7.18 BASES APPLICABLE pool geometry (Ref. 2). There are three basic acceptance SAFETY ANALYSES criteria which ensure conformance with the design bases (continued) (Ref. 3). They are:

a. keff < 1.0 assuming no soluble boron in the fuel storage pool,

b. A soluble boron concentration sufficient to ensure keff < 0. 95, and

c. An additional amount of soluble boron sufficient to offset the maximum reactivity effects of postulated accidents and to account for the uncertainty in the .

computed reactivity of fuel assemblies. assemblies,a fuel assembly The postulated accidents considered when determining drop, required fuel storage pool arrangement and minimum bo concentration are the misleading of~ fuel assemaly, increase in fuel storage pool temperature, and boron dilution. Analyses have shown that a combination of the fuel storage pool geometric arrangement and the amount of boron required by the LCO is sufficient to ensure that the most limiting misleading of.a-fuel a~results in a keff < 0.95. assem bl"res The configuration of fuel assemblies in the fuel storage pool satisfies Criterion 2 of 10 CFR 50.36(c) (2) (ii). 3.7.18-1, 3.7.18-2, and 3.7.18-3, LCO The restrictions on the placement of fuel assemblies with the spent fuel pool, in accordance with Figures 3.7.18 1 \

anci 3,7,1g 2, in the accompanying LCO, ensures the keff of the spent fuel storage pool will always remain < 1.0.

Figure 3.7.18 1 is used to determine if a fuel assemaly is acceptable fer 3terage witheut use of a fuel assemaly tflatrix. Ba3ed e1i the iliitial e111 icl1me11t a11d bu111up, a fuel Insert# 3 Next Page

--- assembly may tie stored w1tl'\Out us1 ng a fue1 assembly matr1 x, 01 must be sto1ed i11 a l1igl1 01 low 1eactivity locatio11 of a fuel assembly mat1ix. Figu1e 3.7.18 2 de3e1ibe3 the fuel assemaly lflatrix storage cenfiguratio11. These storage restrictions, when combined with the fuel storage pool boron concentration limit in LCO 3.7.17, ensure that the fuel storage pool keff meets the limits in Section 4.3, "Design Features."

APPLICABILITY This LCO applies whenever any fuel assembly is stored in the fuel storage pool.

North Anna Units 1 and 2 B 3. 7 .18-2 Revision 0

Insert# 3 for TSB 83. 7.18 LCO:

Figures 3. 7 .18-2 and 3. 7 .18-3 are used to determine if a fuel assembly is acceptable for storage in Region 2 based on its initial enrichment, burnup, and cooling time if it does not contain a full .*

length Rod Cluster Control Assembly (RCCA); if the fuel assembly contains a full length RCCA it may be stored in Region 2 regardless of its initial enrichment/burnup/cooling time. There is no restriction on initial enrichment/burnup/cooling time for fuel assemblies stored in Region 1 and no RCCA is required. Figure 3.7.18-1 shows a typical fuel assembly checkerboard storage arrangement for Region 1. TS 3. 7.18 lists all the requirements for Region 1 fuel storage.

- NUCLEAR DESIGN INFORMATION PORTAL-Spent Fuel Pool Storage B 3.7.18 BASES ACTIONS A.1 Required Action A.1 is modified by a Note indicating that LCO 3.0.3 does not apply.

Insert# 4 Next --7 WheR the coRfi gurati on of fuel assembl i e3 3to1 ed i 11 tl1e Page speRt fuel storage pool is not in accordance with Eig1ire 3 7 18-1 aml FigYre 3.7.18 2, tl1e i1ii111ediate act1on is to i iii ti ate aeti on to make the necessary fael asseFRbly movement(s) to bring the coRfigYratioR iRto coFRpliance with Hie LCO.

If unable to move irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not be applicable. If unable to move irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the action is independent of reactor operation. Therefore, inability to move fuel assemblies is not sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.7.18.1 REQUIREMENTS Thi'.5 SR verifies by a combination of visual iRspectioR and administrative means that the initial enrichment and bYrRup

'Insert# 5 Next Page 1----)3>- of the fael assembly is in aeeo1d1rnce witl1 Figure 3.7.rn-l an El the fuel asseffibl y storage 1oeatio11 i !5 i l'l aeeo rdanee with Figure 3. 7 .18 2 REFERENCES 1. UFSAR, Section 9.1.2.

2. UFSAR, Section 4.3.2.7.

3. UFSAR, Section 3.1.53.

North Anna Units 1 and 2 B 3. 7 .18-3 Revision 0

Insert# 4 for TS8 83. 7 .18 Surveillance Requirements:

When the configuration of fuel assemblies stored in Region 1 of the spent fuel storage pool is not in accordance with the checkerboard arrangement in Figure 3. 7.18-1, or when the initial enrichment/burnup of a fuel assembly stored in Region 2 of the spent fuel storage pool is not in the acceptable domain of Figure 3. 7.18-2 or 3. 7.18-3 if the assembly cooling time is~ 3 years (unless the fuel assembly contains a full length RCCA),the immediate action is to initiate action to make the necessary fuel assembly movement(s) to bring the configuration into compliance with the LCO.

Insert# 5 for TS8 83. 7 .18 Surveillance Requirements:

This SR verifies by a combination of visual inspection and administrative means that a fuel assembly in Region 1 is stored in accordance with the checkerboard arrangement in Figure

3. 7.18-1. This SR also verifies by a combination of visual inspection and administrative means that the initial enrichment, burnup, and cooling time of a fuel assembly stored in Region 2 is in the "Acceptable" burnup domain of Figure 3. 7 .18-2 or Figure 3. 7.18-3. There are no enrichment/burnup/cooling time restrictions if the assembly is stored in Region 1 or contains a full length RCCA if stored in Region 2 other than the initial enrichment must be~ 5.0 weight percent U-235.

Spent Fuel Pool Storage B 3.7.18 B 3.8 PLANT SYSTEMS B 3.7.18 Spent Fuel Pool Storage BASES BACKGROUND The fuel storage pool contains racks which hold the fuel assemblies. The arrangement of the fuel assemblies in the fuel racks can be used to limit the interaction of the fuel assemblies and the resulting reactivity of the fuel in the fuel storage pool. A Region 1 checkerboard arrangement is a rectangle of assemblies, referred to as a 11 block 11 , that can be placed anywhere in the fuel storage pool. The geometric arrangement for Region 1 is based on a 2-out-of-4 checkerboard arrangement, each corner of the Region 1 block being an empty location, and at least two (2) Region 2 rows between Region 1 blocks. A Region 1 block shall not cross a spent fuel rack boundary where a rack module is adjacent to another rack module. This requirement eliminates the need to perform a rack-to-rack misalignment analysis. Rack modules that are adjacent to the spent fuel pool wall may credit the wall region as empty cells for the purposes of meeting the Region 1 requirements of LCO 3.7.18.a.II.i and 3.7.18.a.II.iii since the reactivity of the wall region is bounded by the Region 1 checkerboard storage arrangement.

However, a Rod Cluster Control Assembly (RCCA) and/or cell blocker may be stored in an empty location because RCCAs are strong neutron absorbers and cell blockers are located above the fuel. There is no burnup curve for Region 1 storage.

Fuel assemblies may be stored in Region 2 if they are either in the acceptable burnup domain of the initial enrichment/

burnup curve in Figure 3.7.18-2 or enrichment/burnup curve in Figure 3.7.18-3 for fuel assemblies with a cooling time of three (3) or more years (cooling time is the time elapsed since the last use of a fuel assembly in a critical condition). Any fuel assembly containing a full length RCCA, regardless of enrichment/burnup/cooling time may be stored in Region 2 because the RCCA provides enough negative reactivity to meet the keff requirements. If the enrichment, burnup, and cooling time of a fuel assembly stored in Region 2 is NOT in the 11 Acceptable" burnup domain in Figure 3.7.18-2 or 3.7.18-3 (e.g., the assembly requires a full length RCCA for storage in Region 2), then the assembly must be in a Region 1 storage location when its RCCA is inserted or removed. This requirement prevents the assembly from becoming unqualified for Region 2 storage.

North Anna Units 1 and 2 B 3. 7 .18-1 Revision xx

Spent Fuel Pool Storage B 3.7.18 BASES BACKGROUND Storing the fuel assemblies in the locations required by the (continued) LCO ensures a fuel storage pool keff < 1.0 for normal conditions. In addition, the water in the spent fuel storage pool contains soluble boron, which results in large subcriticality margins under normal operating conditions.

However, the NRC guidelines assume accident conditions, such as loss of all soluble boron or misloading of a fuel assembly.

In these cases, the subcriticality margin is allowed to be smaller, but in all cases must be less than 1.0. This subcriticality margin is maintained by storing the fuel assemblies as described in the LCO and by the use of soluble boron in the fuel storage pool water as required by LCO 3.7.17, "Fuel Storage Pool Boron Concentration." The accident analyses assume the presence of soluble boron under accident conditions, such as the misloading of fuel assemblies into locations not allowed by LCO 3.7.18, a fuel assembly drop, a loss of cooling to the fuel storage pool resulting in a temperature increase of the fuel storage pool water, or a dilution of the boron dissolved in the fuel storage pool.

A general description of the fuel storage pool design is given in the UFSAR, Section 9.1.2 (Ref. 1).

APPLICABLE Criticality of the fuel assemblies in the fuel storage pool SAFETY ANALYSES racks is prevented by the design of the rack and by administrative controls related to fuel storage pool boron concentration, fuel assembly burnup credit, and fuel storage pool geometry (Ref. 2). There are three basic acceptance criteria which ensure conformance with the design bases (Ref. 3). They are:

a. keff < 1.0 assuming no soluble boron in the fuel storage pool, *

b. A soluble boron concentration sufficient to ensure keff < 0.95, and

c. An additional amount of soluble boron sufficient to offset the maximum reactivity effects of postulated accidents and to account for the uncertainty in the computed reactivity of fuel assemblies.

The postulated accidents considered when determining the required fuel storage pool arrangement and minimum boron concentration are the misloading of fuel assemblies, a fuel North Anna Units 1 and 2 B 3.7.18-2 Revision xx

Spent Fuel Pool Storage B 3.7.18 BASES APPLICABLE assembly drop, an increase in fuel storage pool temperature, SAFETY ANALYSES and boron dilution. Analyses have shown that a combination (continued) of the fuel storage pool geometric arrangement and the amount of boron required by the LCO is sufficient to ensure that the most limiting misleading of fuel assemblies results in a keff < 0. 95.

The configuration of fuel assemblies in the fuel storage pool satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The restrictions on the placement of fuel assemblies within the spent fuel pool, in accordance with Figures 3.7.18-1, 3.7.18-2, and 3.7.18-3, in the accompanying LCO, ensures the keff of the spent fuel storage pool will always remain< 1.0.

Figures 3.7.18-2 and 3.7.18-3 are used to determine if a fuel assembly is acceptable for storage in Region 2 based on its initial enrichment, burnup, and cooling time if it does not contain a full length Rod Cluster Control Assembly (RCCA);

if the fuel assembly contains a full length RCCA it may be stored in Region 2 regardless of its initial enrichment/

burnup/cooling time. There is no restriction on initial enrichment/burnup/cooling time for fuel assemblies stored in Region 1 and no RCCA is required. Figure 3.7.18-1 shows a typical fuel assembly checkerboard storage arrangement for Region 1. TS 3.7.18 lists all the requirements for Region 1 fuel storage. These storage restrictions, when combined with the fuel storage pool boron concentration limit in LCO 3.7.17, ensure that the fuel storage pool keff meets the limits in Section 4.3, "Design Features."

APPLICABILITY This LCO applies whenever any fuel assembly is stored in the fuel storage pool.

ACTIONS A.1 Required Action A.1 is modified by a Note indicating that LCO 3.0.3 does not apply.

When the configuration of fuel assemblies stored in Region 1 of the spent fuel storage pool is not in accordance with the checkerboard arrangement in Figure 3.7.18-1, or when the initial enrichment/burnup of a fuel assembly stored in Region 2 of the spent fuel storage pool is not in the acceptable domain of Figure 3.7.18-2 or 3.7.18-3 if the North Anna Units 1 and 2 B 3.7.18-3 Revision xx

Spent Fuel Pool Storage B 3.7.18

,.1 BASES ACTIONS assembly cooling time is> 3 years (unless the fuel assembly (continued) contains a full length RCCA), the immediate action is to initiate action to make the necessary fuel assembly movement(s) to bring the configuration into compliance with the LCO.

If unable to move irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not be applicable. If unable to move irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the action is independent of reactor operation. Therefore, inability to move fuel assemblies is not sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.7.18.1 REQUIREMENTS This SR verifies by a combination of visual inspection and administrative means that a fuel assembly in Region 1 is stored in accordance with the checkerboard arrangement in Figure 3.J.18-1. This SR also verifies by a combination of visual inspection and administrative means that the initial enrichment, burnup, and cooling time of a fuel assembly stored in Region 2 is in the "Acceptable burnup domain of Figure 3.7.18-2 or Figure 3.7.18-3. There are no enrichment/

burnup/cooling time restrictions if the assembly is stored in Region 1 or contains a full length RCCA if stored in Region 2 other than the initial enrichment must be ~ 5.0 weight percent U-235.

REFERENCES 1. UFSAR, Section 9.1.2.

2. UFSAR, Section 4.3.2.7.

3. UFSAR, Section 3.1.53.

North Anna Units 1 and 2 B 3.7.18-4 Revision xx

Serial No.16-383 Docket Nos.: 50-338/339 Page 1 of 13 Attachment 5 CRITICALITY SAFETY EVALUATION CHECKLIST VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1AND2

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 5 Criticality Safety Evaluation Checklist Page 2 of 13 Criticality Safety Evaluation Checklist

, Subject Included Explanation [Section in LAR]

I 1.0 Introduction Purpose of submittal YES Increase enrichment to 5 w/o, simplify storage patterns in the SFP, increase identified k margin [Section 1]

Summary of physical changes (SFP) YES Two regions [Section 1]

Summary of analytical scope YES New fuel storage area and spent fuel pool [Sections 1 and 2]

2.0 Acceptance Criteria and Regulatory Guidance Summary of requirements and guidance YES Requirements documents referenced YES [Section 2]

Guidance documents referenced YES Summary table demonstrating implementation in analysis [Section 2]

Acceptance criteria described YES [Section 2]

3.0 Storage Rack Description New fuel storage rack description YES Sufficient detail for modeling [Section 3.1]

Nominal and tolerance dimensions YES [Section 3.1, Table 3.1]

Schematic representation of rack YES [Section 3.1, Figure 3.3]

Spent fuel storage rack description YES Sufficient detail for modeling [Section 3.2]

Nominal and tolerance dimensions YES [Section 3.2, Table 3.2]

Schematic representation of rack YES [Section 3.2, Figure 3.5 and 3.7]

4.0 Fuel Design Description Describe all fuel in pool YES Range of key parameters all past and present fuel designs [Section 4.1]

Nominal and tolerance dimensions YES [Section 4.1, Table 4.1 and 4.2]

Describe known future fuel to be covered NO None proposed Describe all fuel inserts YES [Section 4.2]

Nominal and tolerance dimensions YES [Section 4.2, Table 4.4]

Describe non-standard fuel YES [Section 4.3, analyzed in Section 12.6]

Describe non-fuel items in fuel cells YES [Section 4.3]

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 5 Criticality Safety Evaluation Checklist Page 3of13 Criticality Safety Evaluation Checklist Subject Included Explanation [Section in LAR]

5.0 Overview of the Method of Analysis New fuel rack analysis description YES [Section 5.0]

Storage geometry restrictions NO Single region, no blocked cells [Section 5:01 Bounding assembly design(s) YES [Section 5 and Sections 7.1.1-7.1.4]

Integral absorber credit NO Accident analysis YES Flooded & Optimum Moderation

[Sections 5 and 7.3]

Spent fuel storage rack analysis description YES Storage geometries YES Two regions [Section 5]

Bounding assembly design(s) YES Bounds old and current fuel designs

[Sections 5 and 8.8]

Boraflex credit NO Modeled as water [Section 5 and Section 9.1]

Aging management program NO No rack neutron poison credited Soluble boron credit YES [Section 5]

Boron dilution analysis NO Previously approved analysis referenced

[Sections 5 and 13.1]

Burnup credit YES Two burnup curve/TRITON depletion

[Section 5]

Decay time credit YES One burn up curve/ TRITON depletion credits 3 year decay time [Sections 5 and 10.6]

Integral absorber credit NO Fixed neutron absorber NO No credit for BPRA storage in fuel Other credit YES With control rod assembly in fuel no burnup is required [Section 5]

Accident analysis YES [Section 5 and Section 13]

Temperature increase YES [Sections 5 and 13.5]

Assembly drop YES [Sections 5 and 13.4]

Multiple misload YES Bounding accident [Sections 5 and 13.2]

Boron dilution YES [Sections 5 and 13.1]

Seismic event YES North Anna earthquake resolution discussed. Region 1 design restrictions prevent interface boundary misalignment if racks slide. No credit for inter-rack spacing. Rack spacing effect discussed. [Section 13.6]

Other YES Fuel handling assemblies within 12" of each other [Section 13.3]

Fuel out of rack analysis YES [Sections 5 and 12]

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 5 Criticality Safety Evaluation Checklist Page 4of13 Criticality Safety Evaluation Checklist Subject Included Explanation [Section in LAR]

Handling YES [Sections 5, 12.1 and 12.2]

Movement YES [Sections 5, 12.1 and 12.2]

Fuel Inspection YES [Sections 5 and 12.4]

6.0 Cross Sections, Computer Codes, and Validation Code/Modules Used for Calculation of kett YES SCALE6.0/CSAS5 - KENO V.a [Sections 5 and 6]

Cross section library YES ENDF/B-Vll 238 Group [Sections 5 and 6.1]

List all the isotopes used YES [Table 6.1]

Convergence checks YES Description of convergence related input, source distribution, kett trends

[Section 6.1.1]

Code/Module Used for Depletion Calculation YES SCALE6.0/T5-depl - KENO V.a [Section 6.1.2]

Cross section library YES ENDF/B-Vll 238 Group [Section 6.1]

List all the isotopes used YES All SCALE 6.0 (T5-DEPL addnux=3),

reduced volatile fission products [Table 6.1]

Convergence checks YES Description of convergence related input, basis for time step sizes, rack kett results confirming convergence [Section 6.1.2]

Validation of Depleted Fuel Isotopic Content YES Use ISG 2010-01 (5% burnup worth).

Confirmatory comparison to CASM0-4 and CASM0-5 depletion reactivity decrement. [Section 6.2]

Validation of Code and Library YES Section 6.2 and 6.3]

Major Actinides and Structural Materials YES [Section 6.3.1 and Appendix A]

Minor Actinides and Fission Products YES 1.5% bias (NUREG/CR-7109) [Section 6.3.2]

Temperature dependence YES LEU-COMP-THERM-046 [Section 6.3.3]

7 .0 Criticality Safety Analysis of the New Fuel Storage Area Rack model YES Full storage area (126 cells plus structure and concrete) [Section 7.1]

Boundary conditions YES Void [Section 7.1]

Source distribution specified NO Code default (uniform in fissile material)

[Section 7.1]

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 5 Criticality Safety Evaluation Checklist Page 5of13 Criticality Safety Evaluation Checklist Subject Included Explanation [Section in LAR]

Limiting fuel design Fuel density YES Bounding high [Sections 7.1 and 8.8.1)

Grids NO Not modeled Burnable Poisons NO No credit Fuel dimensions YES Multiple recent designs considered, bounding [Section 7.1]

Axial blankets NO No blankets have been used [Section 4.1]

Fuel plenum and end plug region NO Modeled as moderator [Section7.1.4]

Limiting rack model Storage area walls YES Bound-water concrete [Section 7.1.7]

Flooded 32° to 100°F Temperature YES Optimum Moderation 32° to 100°F

[Section 7.1.9]

Multiple regions NO New 5.0 w/o fuel allowed in all cells Flooded YES Bias and uncertainty calculated [Section 7.2]

Low density moderator YES Bias and uncertainty calculated [Section 7.2]

Offset all assemblies towards middle of Asymmetric fuel placement YES storage area in rack model [Section 7.1.8]

Tolerances Fuel geometry Fuel pin pitch YES [Section 7.2]

Fuel pellet OD YES [Section 7.2]

Fuel clad ID YES [Section 7.2]

Fuel clad OD YES [Section 7.2]

Guide tube ID YES [Section 7.2]

Guide tube OD YES [Section 7.2]

Axial fuel position YES [Section 7.2]

Axial Fuel Length YES [Section 7.2]

Fuel content Enrichment NO 5.0 w/o is bounding Dish and Chamfer NO Included in Density Density YES [Section 7 .2]

Rack geometry Rack pitch YES [Section 7.2]

Cell wall thickness YES [Section 7 .2]

Concrete Composition NO Bounding Composition [Section 7.1.7]

Concrete wall thickness YES [Section 7.2]

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 5 Criticality Safety Evaluation Checklist Page 6of13 Criticality Safety Evaluation Checklist Subject Included Explanation [Section in LAR]

Support beam size YES [Section 7.2]

Code uncertainty YES EALF extrapolation [Section 7.2]

Absorber geometry and content NO No absorber credit Biases Temperature YES From code benchmarking [Section 7.2]

Code bias YES EALF extrapolation [Section 7.2]

Absorber geometry and content NO No absorber credit Accident analysis Flooding (water and low density moderator) YES [Sections 7.2 and 7.3]

8.0 Depletion Modeling TRITON Depletion Model Considerations Time step verification YES Adequate for isotopic convergence

[Section 6.1.2]

Convergence verification YES More neutron histories than required

- for depletion kettconvergence [Section 6.1.2]

Simplifications YES Described and justified (grids) [Section 8.8.2]

Non-uniform enrichments NO None present Nodalization YES 18 nodes depleted independently

[Section 8.1]

Bounding fuel assembly YES Fuel density, guide tubes, grids, inserts

[Section 8.8]

Fuel clad creep and grid growth YES Evaluated as a bias [Section 10.2]

Limiting depletion parameters Past and present cycles Burnable Absorbers, source rods, inserts YES Max BPRA is bounding. BPRA remains inserted for entire depletion. [Section 8.9]

Integral absorbers NO Maximum BPRA bounds WABA and IFBA (Maximum IFBA plus up to 8 BPRA also analyzed). [Section 8.9]

Soluble Boron YES Bounds all burnup average boron

[Section 8.3]

Fuel and Water Temperature YES Node-specific values based on bounding high power history, TS minimum flow, 18 node burnup (power) shape, SIMULATE fuel temperature tables

[Section 8.6]

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 5 Criticality Safety Evaluation Checklist Page 7 of 13 Criticality Safety Evaluation Checklist Subject Included Explanation [Section in LAR]

Specific power YES Includes all core power uprates, bounding high assembly power history, nodal power proportional to 18 node burnup shape. Low power at EOL effect included as a bias (reduced 50% for last 40 days of depletion). [Section 8.7]

Control rod insertion NO Bounded by BPRA insertion [Section 8.9.2]

Axial burnup shapes YES Uniform and NUREG/CR-6801 used within specified burn up range, justified by comparison to North Anna shapes.

[Section 8.5]

Grids YES Maximum volume Zircaloy grids [Section 8.8.2]

In-core flux mapping thimble YES Not in base depletion model, but effect evaluated and included as a bias

[Section 8.9.4]

Depleted fuel content nuclide selection Number of nuclides YES All TRITON nuclides included [Section 6.1.2]

Volatile fission products YES Reduced based on release fractions

[Section 6.1.1]

Decay time YES 5 days (base burnup curve) and 3 years (decay time credit) [Section 6.1.2, 8.10]

9.0 Region 1 Analysis Rack model YES 6x6 model with asymmetric fuel placement [Section 9.1]

Boundary conditions YES Periodic X-Y, mirror Z [Section 9.1]

Source distribution specified NO Default (uniform in fissile material)

Model simplifications YES Minor simplifications justified [Section 9.1]

Geometry restrictions YES 2 out of 4 checkerboard, Region interface requirements [Section 9.1]

Non-fuel component storage YES Evaluated [Section 9.5]

Limiting fuel design Fuel density YES Bounds all fuel batches [Section 8.8.1]

Grids YES Minimum volume Zr grids (included as a bias) [Section 8.8.2, 9.2.1]

Burnable Poisons NO No credit [Section 9.6]

Fuel assembly inserts NO Bounded by fuel assembly only [Section 12]

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 5 Criticality Safety Evaluation Checklist Page 8of13 Criticality Safety Evaluation Checklist Subject Included Explanation [Section in LAR]

Fuel dimensions YES All fuel designs in SFP considered

[Section 9.1)

Axial blankets NO Configuration(s) considered YES Region 1 (2/4 fresh 5.0 w/o fuel)

[Section 9.1]

Un borated YES Full bias and tolerance calculations for fresh fuel [Section 9.3]

Borated YES Some borated bias and tolerance calculations, 1% ~K additional NRC review margin [Section 9.3]

Multiple rack designs NO All racks are the same Boraflex flux trap design [Section 3.2]

Alternate storage geometry NO Axial burnup shapes NO No burnup credit in Region 1 [Section 9.3]

Tolerances Fuel geometry Fuel pin pitch YES [Section 9.3]

Fuel pellet OD YES [Section 9.3]

Fuel clad ID YES [Section 9.3]

Fuel clad OD YES [Section 9.3]

Guide tube ID YES [Section 9.3]

Guide tube OD YES [Section 9.3]

Axial fuel position YES [Section 9.3]

Fuel stack height YES [Section 9.3]

Fuel content Enrichment NO 5.0 w/o is bounding [Section 9.3]

Density YES [Section 9.3]

Burnup worth NO No burnup credit in Region 1 Measured burnup NO No burnup credit in Region 1

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 5 Criticality Safety Evaluation Checklist Page 9of13 Criticality Safety Evaluation Checklist Subject Included Explanation [Section in LAR]

Rack geometry Cell wall thickness YES [Section 9.3]

Rack cell pitch YES [Section 9.3]

Rack cell inside dimension YES Evaluated but not included in total uncertainty [Section 9.2.2, 9.3]

Boraflex wrapper thickness YES [Section 9.3]

Boraflex wrapper height NO Captured via axial fuel position variation Rack tie plate thickness and width YES [Section 9.3]

Code uncertainty YES [Section 9.3]

KENO case uncertainty YES 2 standard deviations [Section 9.3]

Biases Fuel geometry Minimum grid volume YES [Section 9.3]

Code bias YES [Section 9.3]

Temperature YES 32 F to 140 F plus code benchmark temperature bias [Section 9.3]

NRC review margin YES 1% ~k [Section 9.3]

10.0 Region 2 Analysis Rack model YES 6x6 model with asymmetric fuel placement [Section 10.1]

Boundary conditions YES Periodic X-Y, mirror Z [Section 9.1]

Source distribution specified NO Default (uniform in fissile material)

Model simplifications YES Minor simplifications justified [Section 9.1, 10.1]

Geometry restrictions and non-standard items YES Region interface requirements [Section 11]

Non-fuel component storage YES Evaluated [Section 10.10]

Control rod credit with fresh 5.0 w/o fuel YES Evaluated using depleted RCCA model

[Section 10.7]

Fuel rod storage rack with fresh 5.0 w/o fuel YES Evaluated using depleted RCCA model

[Section 10.9]

Limiting fuel design Fuel density YES Bounds all fuel batches [Section 8.8.1]

Grids YES Minimum volume Zr grids (included as a bias) [Section 10.4.1]

Burnable Poisons NO No credit Fuel assembly inserts NO Bounded by fuel assembly only [Section 12]

Fuel dimensions YES All fuel designs in SFP considered

[Section 9.1]

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 5 Criticality Safety Evaluation Checklist Page 10of13 Criticality Safety Evaluation Checklist Subject Included Explanation [Section in LAR]

Axial blankets NO Configurations considered YES 4/4 with burn up credit or control rod credit [Section 10.1]

Un borated YES Full bias and tolerance calculations for fresh fuel, most bias and tolerances calculated for depleted fuel [Sections 10.4, 10.5, 10.6 and 10.7]

Borated YES Some borated bias and tolerance calculations, 1% ~K additional NRC review margin [Section 10.8]

Multiple rack designs NO All racks are the same Boraflex flux trap design Alternate storage geometry NO Axial burnup shapes Non-uniform with justification YES NUREG/CR-6801, except shape 9

[Sections 8.5 and 10.1]

Uniform YES 0 to 30 GWd/MTU [Section 10.1]

Region interface effects (mixed shapes) YES Analyzed uniform and non-uniform shapes at minimum and maximum burnup [Section 11]

Tolerances Fuel geometry Fuel pin pitch YES [Sections 10.5, 10.6 and 10.7]

Fuel pellet OD YES Fresh fuel, applied to all burnups

[Sections 10.5, 10.6 and 10.7]

Fuel clad ID YES Fresh fuel, applied to all burnups

[Sections 10.5, 10.6 and 10.7]

Fuel clad OD YES Fresh fuel, creep bias for depleted

[Sections 10.5, 10.6 and 10.7]

Guide tube ID YES Fresh fuel, applied to all burnups

[Sections 10.5, 10.6 and 10.7]

Guide tube OD YES Fresh fuel, applied to all burnups

[Sections 10.5, 10.6 and 10.7]

Axial fuel position YES [Sections 10.5, 10.6 and 10.7]

Fuel stack height YES Fresh fuel, applied to all burnups

[Sections 10.5, 10.6 and 10.7]

Control rod absorber OD YES For RCCA credit only [Sections 10.7]

Control rod clad OD YES For RCCA credit only [Sections 10.7]

Fuel content Enrichment YES [Sections 10.5 and 10.6]

Density YES [Sections 10.5, 10.6 and 10.7]

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 5 Criticality Safety Evaluation Checklist Page 11 of 13 Criticality Safety Evaluation Checklist Subject Included Explanation [Section in tAR]

Burnup worth YES 5% of burn up worth [Sections 10.5 and 10.6]

Measured burnup YES 4% of burnup worth [Sections 10.5 and 10.6]

Rack geometry Cell wall thickness YES [Sections 10.5, 10.6 and 10.7]

Rack cell pitch YES [Sections 10.5, 10.6 and 10.7]

Boraflex wrapper thickness YES [Sections 10.5, 10.6 and 10.7]

Boraflex wrapper height NO Captured via axial fuel position variation Rack tie plate thickness and width YES [Sections 10.5, 10.6 and 10.7]

Code uncertainty YES [Sections 10.5, 10.6 and 10.7]

KENO case uncertainty YES 2 standard deviations [Sections 10.5, 10.6 and 10.7]

Biases Fuel geometry Clad creep YES [Sections 10.5 and 10.6]

Grid growth (pin pitch) YES [Sections 10.5 and 10.6]

Minimum grid volume YES [Sections 10.5, 10.6 and 10.7]

Minor actinides and fission product worth YES 1.5% of worth {NUREG/CR-7109)

[Sections 10.5 and 10.6]

Code bias YES Temperature YES 32 F to 140 F plus code benchmark temperature bias [Sections 10.5, 10.6 and 10.7]

Low power at EOL YES [Sections 10.5 and 10.6]

Horizontal burnup tilt YES [Sections 10.5 and 10.6]

lncore thimble depletion effect YES [Sections 10.5 and 10.6]

NRC review margin YES 1% ~k [Sections 10.5, 10.6 and 10.7]

11.0 Interface Analysis Region interface effects YES Calculated [Section 11]

Region 1 interface requirements YES Specified [Section 11]

12.0 Normal Conditions Fuel handling equipment YES Bounding analysis [Sections 12.1 and 12.2]

Failed fuel storage cans YES Bounding analysis [Section 12.3]

Fuel inspection equipment or processes YES Bounding analysis [Section 12.4]

Fuel reconstitution I damaged fuel YES Bounding analysis [Sections 12.5 and 12.6]

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 5 Criticality Safety Evaluation Checklist Page 12of13 Criticality Safety Evaluation Checklist Subject Included Explanation [Section in LAR]

13.0 Accident Analysis Boron dilution YES 0 ppm k < 1.0 including biases and uncertainties [Sections 9, 10, 11 and 12]

Normal conditions YES k < 0.95 with boron less than minimum dilution analysis boron [Section 13.1]

Multiple fuel misload YES Fresh 5.0 w/o fuel in all cells [Section 13.2]

Fuel handling YES Fuel closer than 12 inches apart out of racks [Section 13.3]

Dropped or mis-loaded assembly YES Not limiting [Section 13.4]

Temperature YES 32 F to 212 F and 20% voiding [Section 13.5]

Heavy load drop NO Not Analyzed. Heavy loads over the spent fuel pool are restricted by procedure. [Section 13.4]

Seismic event NO Not analyzed due to use of infinite lattice models with no rack spacing credit, Region 1 contained within rack modules, benign Region boundaries.

Discussion of North Anna 2011 seismic event, increased rack spacing sensitivity

[Section 13.6]

14.0 Summary and Conclusions Summary of results YES [Section 14]

Loading curves YES Bounding cubic equations [Section 14.4]

Region 1 placement constraints YES Restrictions listed [Section 14.1]

Bounding fuel design and depletion data YES Listed [Sections 14.2 and 14.3]

Other storage restrictions YES Listed [Section 14.4]

Update SFP fuel handling procedures to prohibit fuel from coming within 12 New administrative controls YES inches of each other outside racks during fuel handling [Section 14.5]

- .,.... -- - - - -- - - ----- - - -*- --- ----- - --*-- -- - - ~ - -- - -- ---- - - -~ ~ -- - - - --- - ." - - -- - - ----- --- --- -- -~- - -- - - ---

Appendix A Computer Code Validation:

Code validation methodology and bases YES NUREG 6698 Method [Section A.1.]

New Fuel YES [Sections A.3.1. and A.5.1.]

Depleted Fuel YES [Sections A.3.2., A.4. and A.5.2.]

MOX critical YES Included for spent fuel HTC critical YES Included for spent fuel High temperature criticals YES Included, added bias [Section A.8.]

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 5 Criticality Safety Evaluation Checklist Page 13of13 Criticality Safety Evaluation Checklist r:-~': .,,~-~'¥'*. -

.. -**-subjffct . *..

T.

Included *> :Explanation [Section;in LARJ Convergence YES Neutron histories and trends [Section A.4.]

Trends YES [Sections A.5.1. and A.5.2.)

Bias and uncertainty YES [Section A.7.]

Range of applicability YES [Section A.6.]

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 8 AFFIDAVIT OF AREVA NP, INC.

VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1AND2

A E A October 31, 2016 FAB 16-00630 Mr. Brian Vitiello Dominion Resources Services, Inc.

Innsbrook Technical Center, 3rd, SW 5000 Dominion Boulevard Glen Allen, VA 23060

Subject:

Affidavit Supporting AREVA Proprietary Information Contained in Dominion's North Anna Power Station Licensing Amendment Request Reference 1: Fuel Fabrication and Related Services Contract between Dominion Nuclear Connecticut, Inc and AREVA NP, Inc. dated February 1, 2011 as amended through Amendment 3, dated November 2, 2015.

Reference 2: Request for Proprietary Affidavit to Support North Anna Power Station Licensing Amendment Request, CORRES-OUT-AREVA-20160065 Rev. 0, dated October 12, 2016, from Mike Lico. AREVA document 38-9264076-000.

Dear Mr. Vitiello,

The attached Affidavit supports Dominion's use of AREVA proprietary information in Dominion's Licensing Amendment Request (LAR) that will revise the North Anna Power Station spent fuel pool criticality analysis. The information identified as proprietary in Reference 2 had previously beeri supplied to Dominion in AREVA documents as proprietary.

Note that the attached contains AREVA Proprietary data and is to be treated according to Reference

1. If you have any questions or comments, feel free to call me at (434) 832-5029, or you can e-mail me at Hunter.Marshall@areva.com.

E. Hunter Marshall Project Manager Cc: Chris Clemens Tom Brookmire Cary Laroe John Harrell Stacey Nelson Michael Lico AREVA INC..

3315 Old Forest l~oad, Lynchburg, VA 24501 Te!.: 434 832 3000 ~ wY.1w.areva.com AREVA PROPRIETARY This document and any information contained herein, is the property of AREVA Inc. (AREVA) and is to be considered proprietary and confidential and may not be reproduced or copied in whole or in part. Nor may it be furnished to others without the express written consent and permission of AREVA, nor may it be used in any way that is or may be detrimental to AREVA. This document and any copies that may have been made must be returned to AREVA upon request.

• AFFIDAVIT COMMONWEALTH OF VIRGINIA SS.

CITY OF LYNCHBURG

1. My name is Gayle Elliott. I am Deputy Director, Licensing & Regulatory Affairs, for AREVA Inc. (AREVA) and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary. I am familiar with the policies established by AREVA to ensure the proper application of these criteria.

3. I am familiar with the AREVA information contained in the Attachment to a letter from Mr. Mark Sartain (Dominion Generation) to U.S. NRC entitled, "Virginia Electric and Power Company North Anna Power Station Units 1 and 2 Proposed Technical Specification Change for Spent Fuel Storage and New Fuel Storage," Cover Letter# 16-383, and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA Inc. for the control and protection of proprietary and confidential information.

• 4. This Document contains information of a prqprietary and confidential nature and is of the type customarily held in confidence by AREVA and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is

requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."

6. The following criteria are customarily applied by AREVA to determine whether info~mation should be classified as proprietary:

(a) The information reveals details of AREVA's research and development plans and programs or their results.

(b) Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.

(c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for AREVA.

(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability.

(e) The information is vital to a competitive advantage held by AR~VA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA.

The information in this Document is considered proprietary for the reasons set forth in paragraphs 6(c), 6(d) and 6(e) above.

7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. AREVA policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.

9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

SUBSCRIBED before me this _?t'\

__7""'_

dayof b~ I 2016, Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/18 Reg.# 7079129 SHERRY L. McFADEN Notary* Public comllio.nweilth of v1ro1n11

. 7079t29 My Comm111'10~ EXPl.rH*0Ct31,.201'8

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 9 AFFIDAVIT OF WESTINGHOUSE ELECTRIC COMPANY, LLC (Westinghouse information only)

VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2

Westinghouse Non-Proprietary* Class 3

@Westinghouse Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066.

USA .

U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document' Control Desk Direct fax: (724) 940-8560 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 CAW-16-4510 November 18, 2016 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

Review of North Anna Fuel Data for Dominion New Fuel Storage Area ~nd Spent Fuel Pool (Proprietary)

The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC ("Westinghouse"), pursuant to the provisions of paragraph (b)(l) of Section 2.390 of the Commission's regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.

The proprietary infonnation for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-16-4510 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CPR Section 2.390 of the Commission's regulations. *

• The subject document was prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that the document be considered proprietary in its entirety. As such, a non-proprietary version will not be issued.

• Accordingly, t~~s letter authorizes the utilization of the accompanying Affidavit by Dominion.

Correspondence with respect to* the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-16-4510, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberr}r Township, Pennsylvania 16066.

j~

f-James A. Gresham, Manager Regulatory Compliance *

© 2016 Westinghouse Electric Company LLC. All Rights Reserved.

CAW-16-4510 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

SS COUNTY OF BUTLER:

I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC ("Westinghouse"), and that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.

ames A. Gresham, Manager Regulatory Compliance

3 CAW-16-4510 (1) I am Manager, Regulatory Compliance, Westinghouse Electric Company LLC ("Westinghouse"),

and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily h~ld in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in

• confidence. The application of that system and the substance of that system constitute Westinghouse policy and provide the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

4 CAW-16-4510 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved

. marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reve;ils cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer fonded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

(iii) There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to.

sell products and services involving the use of the information.

(c) *Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

5 CAW-16-4510 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse ofa competitive advantage.

(e) Uit!estricted disclosure would jeopardize the position of prominence of Westinghouse in the WQrld market, and thereby give a market advantage to the competition of those countries.

..;.

(f) The Westinghouse capacity to invesfcorporate assets.in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iv) The information is being transmitted to the Commission in confidence and, under.the provisions of IO CFR Section 2.390, is to be received in confidence by the Commission.

(v)

• The information sought to be protected is not available in public soQrces or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in SFDT-16-98, Revision 1, "Review of North Anna Fuel Data for

• Dominion New Fuel Storage Area and Spent Fuel Pool" (Proprietary), for submittal to the Commission, being transmitted by Dominion letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with spent fuel pool storage information for criticality analyses, and may be used only for that purpose.

(a)

• This information is pa.rt of that which will enable Westinghouse to perform spent fuel pool analyses.

(b) Further, this information has substantial commercial value as follows:

6 CAW-16-4510 (i) Westinghouse plans to sell the use of similar information to its customers.

for ihe purpose of spent fuel pool analysis.

(ii) Westinghouse can sell support and defense of industry guidelines and .*

acceptance criteria for plant-specific applications.

(iii) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerabl~ sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

---

~

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and non-proprietary versions of a document, furnished to the NRC in connection with requests for genedc. and/or plant-specific review and approv_al.

In order to conform to the requirements of 10 CPR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the"infomiation that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CPR 2.390(b)(l).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CPR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in' local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 10 AFFIDAVIT OF ELECTRIC POWER RESEARCH INSTITUTE, INC.

AND AREVA VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1AND2

~~~11 ELECTRIC POVifER

-=*-le; RESEARCM INSTITUTE KENNETH CANAVAN Director, Plant Technology December 13, 2016 Mr. Michael S. Lico Dominion Resources, Inc.

Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, VA 23060-3308

Subject:

Request for Withholding of the following EPRI and AREVA Proprietary Data Extracted from the Following EPRI "Restricted" Technical Report:

EPRI Report 1018642 "Post-Irradiation Examination of AREVA MS Guide Tubes and Fuel Rods Irradiated in North Anna 1 and 2" {March 2009).

Mr. Lico:

This letter from the Electric Power Research Institute ("EPRI") serves as permission for Dominion Resources; Inc.

("Dominion") to include EPRI and AREVA, Inc. ("AREVA") intellectual property and proprietary information in a Licensing Amendment Request (LAR) for the specific purpose of updating the North Anna spent fuel pool ciriticality analysis.

Additionally, this is a request under 10 C.F.R. §2.390(a)(4) that Dominion and the U.S. Nuclear Regulatory Commission ("NRG") withhold from public disclosure the information identified in the enclosed Affidavit consisting of the proprietary information owned/held by EPRI and AREVA identified above {the "Report").

EPRI and ARVEVA desire to disclose the report in confidence at the request of Dominion. The information and data extracted from the Report is not to be divulged to anyone outside of the NRC or to any of its contractors, nor shall any copies be made of the information and data provided herein. EPRI welcomes any discussions and/or questions relating to the information enclosed.

If you have any questions about the legal aspects of this request for withholding, please do not hesitate to contact me at (704) 595-2731. Questions on the identified information and data extracted from the Report should be directed to Rob Daum of EPRI at (704) 595-2779.

Sincerely, 1f.;n;_s: .s).1il!,.;~. -~,. ~.._..._~

c: B. Blackwell R. Daum C. Olexik R. Stark Together ... Shaping the Future of Electricity CHARLOTTE OFFICE 1300 West W.T. Harris Boulevard, Charlotte, NC 28262-8550 USA* 704.595.2000

• Fax 704.595.2860 Customer Service 800.313.3774

• www.epri.com

~~1211

-=*- ELECTRIC POWER RES~ARCH !NST!IUTE AFFIDAVIT RE: Request for Withholding Information and Data Extracted from the Following Proprietary Document:

EPRI Report 1018642 "Post-Irradiation Examination of AREVA M5 Guide Tubes and Fuel Rods Irradiated in North Anna 1 and 2" (March 2009).

The signatories below, being duly sworn, depose and state as follows:

We represent respectively the Electric Power Research Institute, Inc., whose principal office is located at 3420 Hillview Avenue, Palo Alto, California ("EPRI"), and AREVA, Inc., whose principal office is located at 7207 IBM Drive, Charlotte, North Carolina 28262 ("AREVA"). We have been specifically delegated respectively by our companies the responsibility for the information and data extracted from the above-listed Report that is sought under this Affidavit to be withheld (the "Reports"). We are authorized to apply to the U.S. Nuclear Regulatory Commission

("NRC") for the Withholding of the Report.

EPRI and AREVA request that the information and data extracted from the Report be withheld from the public on the following bases:

Withholding Based Upon Privileged And Confidential Trade Secrets Or Commercial Or Financial Information (see e.g. 10 C.F.R. §2.390(a)(4))::

a. The Report is an EPRI publication, and EPRI and AREVA each owns some proprietary information contained in the Report, which has been held in confidence by EPRI and AREVA. All entities accepting information and data extracted from the Report do so subject to written agreements imposing an obligation upon the recipient to maintain the confidentiality of the informantion, data and Report. The Report and informantion and data herein are disclosed only to parties who agree, in writing, to preserve the confidentiality thereof.

b. EPRI considers the Report and the proprietary information contained therein (the "Proprietary Information") to constitute trade secrets of EPRI. As such, EPRI holds the Reports in confidence and disclosure thereof is strictly limited to individuals and entities who have agreed, in writing, to maintain the confidentiality of the Report. EPRI and AREVA made a substantial economic investment to develop the Report, and, by prohibiting public disclosure, EPRI and AREVA derive an economic benefit in the form of licensing royalties and other additional fees from the confidential nature of the Report. If the Report and the Proprietary Information were publicly available to consultants and/or other businesses providing services in the electric and/or nuclear power industry, they would be able to use the Report for their own commercial benefit and profit and without expending the substantial economic resources required of EPRI and AREVA to develop the Report.

c. EPRl's classification of the Report and the Proprietary Information as trade secrets is justified by the Uniform Trade Secrets Act which California adopted in 1984 and a version of which has been adopted by over forty states. The California Uniform Trade Secrets Act, California Civil Code §§3426 - 3426.11, defines a "trade secret" as follows:

"'Trade secret' means information, including a formula, pattern, compilation, program device, method, technique, or process, that:

(1) Derives independent economic value, actual or potential, from not being generally known to the public or to other persons who can obtain economic value from its disclosure or use; and (2) Is the subject of efforts that are reasonable under the circumstances to maintain its secrecy."

d. The Report and the Proprietary Information contained therein are not generally known or available to the public. EPRI developed the Report only after making a determination that the Proprietary Information was not available from public sources. EPRI made a substantial investment of both money and employee hours in the development of the Report. EPRI required to devote these resources and effort to derive the Proprietary Information and the Report. As a result of such effort and cost, both in terms of dollars spent and dedicated employee time, the Report is highly valuable to EPRI.

e. A public disclosure of the Proprietary Information would be highly likely to cause substantial harm to EPRl's competitive position and the ability of EPRI to license the Proprietary Information both domestically and internationally. The Proprietary Information and Report can only be acquired and/or duplicated by others using an equivalent investment of time and effort.

Each signatory below has read the foregoing and affirmed that the matters stated herein are true and correct to the best of his/her knowledge, information and belief.

For EPRI:

I make this affidavit under penalty of perjury under the laws of the United States of America and under the laws of the State of North Carolina.

Executed at 1300 W WT Harris Blvd being the premises and place of business of Electric Power Research Institute, Inc.

(State of North Carolina)

(County of Mecklenburg)

Subscribed and sworn to (or affirmed) before me on this 13,.ay of fJ~, 2016, by

--~'-'-"'WIM~

..........~~-~..---C~a-m.._..1)4,.......r.<_dh1~,_____, proved to me on the basis of satisfactory evidence to be the person(s) who ?{'eared before me.

Signature ~ ;2/. zf:Ollt:f: (Seal)

..r.'+b~p..H H.~0 ,,,

.. ,~lir(;( , 20\f>,

SHERRYL. MCFAD~N N~iry Publlc Commonw1111h or Virginia 7079129

. My commr..io" ~x~rres Oct 31.* 2018

Serial No.16-383 Docket Nos.: 50-338/339 Attachment 11 AFFIDAVIT OF WESTINGHOUSE ELECTRIC COMPANY, LLC (regarding information co-owned with EPRI)

VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1AND2

Westinghouse Non-Proprietary Class 3

@Westinghouse Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 940-8560 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 CAW-16-4513 December 13, 2016 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

Request from Dominion Generation to Transmit Westinghouse-owned Intellectual Property Contained in "Criti~ality Safety Evaluation of the North Anna New Fuel Storage Area and Spent Fuel Pool Allowing 5 wt% U-235 Enriched Fuel" (Proprietary)

The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC ("Westinghouse"), pursuant to the provisions of paragraph (b)(l) of Section ;2.390 of the Commission's regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-16-4513 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Dominion.

Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-16-4513, and should be addressed to James A. Gresham, Mii.riager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.

~~

'/J;ames A. Gresham, Manager Regulatory Compliance

© 2016 Westinghouse Electric Company LLC. All Rights Reserved.

CAW-16-4513 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

SS COUNTY OF BUTLER:

I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC ("Westinghouse"), and that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.

Regulatory Compliance G

Date: __..l--'tl"--ts...__ff _ _ __

3 CAW-16-4513 (1) I am Manager, Regulatory Compliance, Westinghouse Electric Company LLC ("Westinghouse"),

and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for detennining the types of infonnation customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitute Westinghouse policy and provide the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the Joss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

.___j

l 4 CA W-16-4513 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(t) It contains patentable ideas, for which patent protection may be desirable.

(iii) There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

5 CAW-16-4513 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iv) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, is to be received in confidence by the Commission.

(v) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in "Criticality Safety Evaluation of the North Anna New Fuel Storage Area and Spent Fuel Pool Allowing 5 wt% U-235 Enriched Fuel" (Proprietary),

for submittal to the Commission, being transmitted by Dominion letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with spent fuel pool storage information for criticality analyses, and may be used only for that purpose.

(a) This information is part of that which will enable Westinghouse to perform spent fuel pool analyses.

(b) Further, this information has substantial commercial value as follows:

6 CAW-16-4513 (i) Westinghouse plans to sell the use of similar information to its customers for the purpose of spent fuel pool analysis.

(ii) Westinghouse can sell support and defense of industry guidelines and acceptance criteria for plant-specific applications.

(iii) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this pr9prietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure ofa considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and non-proprietary versions of a document, furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to confonn to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the infonnation so designated as proprietary is indicated in both versions by means of lower case letters (a) through (t) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such infonnation. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(t) of the Affidavit accompanying this transmittal pursuant to 10 CPR 2.390(b)(1 ).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.