Dominion Nuclear Connecticut, Inc. Dominion® · Dominion® 5000 Dominion Boulevard, Glen Allen, VA 23060 Web Address: Proprietary Information - Withhold Under 10 CFR 2.390 December

Dominion Nuclear Connecticut, Inc. •.' Dominion®5000 Dominion Boulevard, Glen Allen, VA 23060

Web Address: www.dom.com

Proprietary Information - Withhold Under 10 CFR 2.390

December 17, 2012

U.S. Nuclear Regulatory Commission Serial No. 12-678Attention: Document Control Desk NSSL/MAE ROWashington, DC 20555 Docket No. 50-336

License No. DPR-65

DOMINION NUCLEAR CONNECTICUT. INC.MILLSTONE POWER STATION UNIT 2LICENSE AMENDMENT REQUEST REGARDING PROPOSED TECHNICALSPECIFICATIONS CHANGES FOR SPENT FUEL STORAGE

Pursuant to 10 CFR 50.90, Dominion Nuclear Connecticut, Inc. (DNC) requests anamendment, in the form of changes to the Technical Specifications (TS) to FacilityOperating License Number DPR-65 for Millstone Power Station Unit 2 (MPS2). Theproposed changes will revise TS 1.39 "Storage Pattern," TS 3.9.18, "Spent Fuel Pool -Storage," TS 3.9.19, "Spent Fuel Pool - Storage Patterns," TS 5.3.1 "Fuel Assemblies," TS5.6.1, "Criticality," and TS 5.6.3, "Capacity." Conforming changes are being made toTechnical Specifications Bases (TSB) 3/4.9.18 and 3/4.9.19. These changes reflect theresults and constraints of a new criticality safety analysis for fuel assembly storage in theMPS2 fuel storage racks.

The proposed changes have been reviewed and approved by the Facility Safety ReviewCommittee.

The proposed amendment implements the following conditions associated with fuelstorage at MPS2. The changes are being requested to allow removal of Boraflex credit:

* Eliminate reactivity credit for Boraflex panels in current regions A and B of the spentfuel pool.

* Revise allowed storage patterns for fuel in the spent fuel pool to meet Keffrequirements under normal and accident conditions.

" Revise alphanumeric designation of spent fuel regions from Regions A, B, and C toRegions 1, 2, 3, and 4 to reflect storage requirements and to clearly distinguish fromexisting designations.

* Require use of control element assemblies or borated stainless steel poison rodletsfor fuel assemblies stored in Region 3.

" Eliminate requirement to use spent fuel rack-cell blocking devices.

Attachment 4 contains information that is being withheld from publicdisclosure under 10 CFR 2.390. Upon separation from the attachment, this

letter is decontrolled.

Serial No. 12-678Docket No. 50-336

Proposed LAR - Criticality AnalysisPage 2 of 4

Information provided in the attachments to this letter is summarized below:

- Attachment 1 provides Description, Criticality Technical Analysis, RegulatoryAnalysis and Environmental Analysis of the proposed changes. As discussed inthis attachment, the proposed amendment does not involve a significant hazardsconsideration pursuant to the provisions of 10 CFR 50.92.

- Attachment 2 contains marked-up pages to reflect the proposed changes to the TS.

- Attachment 3 contains marked-up pages to reflect the proposed changes to the TSBases for information only.

- Attachment 4 contains the criticality safety analysis report with informationproprietary to DNC, AREVA NP, and Westinghouse Electric Company, LLC(Proprietary).

- Attachment 5 contains the criticality safety analysis report (Non-Proprietary).

- Attachment 6 contains the AREVA NP affidavit.

- Attachment 7 contains the Westinghouse Electric Company, LLC (Westinghouse)Application for Withholding Proprietary Information from Public Disclosure CAW-12-3573 and accompanying affidavit.

- Attachment 8 contains the Dominion Resources Services, Inc. affidavit.

Since Attachment 4 contains information proprietary to AREVA NP, Inc. (AREVA),Westinghouse, and DNC, it is supported by affidavits signed by the owners of theinformation. The affidavits set forth the basis on which the information may be withheldfrom public disclosure by the Commission and addresses with specificity theconsiderations listed in paragraph (b)(4) of 10 CFR 2.390.

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

DNC requests approval of the proposed amendment by December 31, 2014, whichsupports planned spent fuel pool management activities to eliminate credit for Boraflexpanels in the spent fuel racks. Once approved, the amendment will be implemented bySeptember 1, 2015 (to allow time to load multiple dry storage casks and rearrange fuel inthe spent fuel pool).

In accordance with 10 CFR 50.91(b), a copy of this license amendment request is beingprovided to the State of Connecticut.



Correspondence with respect to the information proprietary to Westinghouse or thesupporting Westinghouse affidavit should reference CAW-12-3573 and should beaddressed to James A. Gresham, Manager, Regulatory Compliance, WestinghouseElectric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township,Pennsylvania 16066.

Should you have any questions in regard to this submittal, please contact Wanda D. Craftat (804) 273-4687.Sincerely,

J. AI ice __. . .V____. ___. . .Vice President- Nuclear Engineering IVICKI L. HULL I

Notary PublicS Commonwealth of Virginia

140542COT OIMy Commission Expires May 31. 2014..

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid,today by J. Alan Price, who is Vice President - Nuclear Engineering of Dominion Nuclear Connecticut, Inc.He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf ofthat Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this _1._7__day of D4C~e.tir, 2012.

My Commission Expires: Al ; rijq .

Notary Public

Commitments made in this letter: None

Attachments:

1. Discussion of Technical Specifications Changes2. Marked-up Technical Specifications Pages3. Marked-up Technical Specifications Bases Pages for Information Only4. Criticality Safety Analysis Report (Proprietary)5. Criticality Safety Analysis Report (Non-Proprietary)6. Affidavit of AREVA NP, Inc.7. Affidavit of Westinghouse Electric company, LLC8. Affidavit of Dominion Resources Services, Inc.



cc: U.S. Nuclear Regulatory CommissionRegion I2100 Renaissance BlvdSuite 100King of Prussia, PA 19406-2713

James S. KimProject ManagerU.S. Nuclear Regulatory CommissionOne White Flint North, Mail Stop 08 C2A11555 Rockville PikeRockville, MD 20852-2738

NRC Senior Resident InspectorMillstone Power Station

DirectorBureau of Air ManagementMonitoring and Radiation DivisionDepartment of Environmental Protection79 Elm StreetHartford, CT 06106-5127


Proposed LAR - Criticality AnalysisAttachment 1

Attachment 1

Evaluation of Technical Specifications Changes

DOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 2


Proposed LAR - Criticality AnalysisAttachment 1Page 1 of 20

Evaluation of Technical Specifications Changes

Table of Contents

1.0 Sum m ary Description ........................................................................................ 3

2.0 Detailed Description of Proposed Technical Specifications Changes ............ 5

2.1 TS 1.39 - Definitions ................................................................................ 5

2.2 TS 3.9.18 - Spent Fuel Pool - Storage .................................................... 5

2.3 TS 3.9.19 - Spent Fuel Pool - Storage Pattern ......................................... 7

2.4 TS 5.3.1 - Fuel Assemblies ....................................................................... 8

2.5 TS 5.6.1 - C riticality ................................................................................. 8

2.6 TS 5.6.3 - Capacity ........................................ 9

3.0 Discussion ....................................................................................................... 9

3.1 Introduction .................................................. ............................................ 9

3.2 Current MPS2 Spent Fuel Configuration .............................................. 10

4.0 Technical Evaluation Sum m ary ............................................................................. 11

4.1 Introduction ........................................................................................... 11

4.2 Spent Fuel Pool Criticality Analysis - General ....................... 11

4.3 Spent Fuel Pool Criticality Analysis - Normal Storage Conditions .......... 12

4.4 Spent Fuel Pool Criticality Analysis - Accident Conditions ............... 13

4.5 Boron Dilution Analysis ........................................................................ 14

4.6 Boraflex Material Monitoring ................................................................... 15

4.7 Decreased Fuel Storage ......................................................................... 15

4.8 Implementation Considerations ........................................................... 15

4.9 Conclusions ............................................................................................. 15



5.0 Regulatory Evaluation ....................................................................................... 16

5.1 Applicable Regulatory Requirements and Criteria .............................. 16

5.2 No Significant Hazards Consideration .................................................. 16

5.3 Precedents ................................................................... ...........................;19

5.4 Conclusion .............................................................................................. 20

6.0 Environm ental Considerations ........................................................................ 20

7.0 References ............................................................................................................. 20



1.0 Summary Description

Dominion Nuclear Connecticut, Inc. (DNC) hereby proposes to amend Operating LicenseDPR-65 by incorporating the enclosed proposed changes into the Technical Specifications(TS) of Millstone Power Station Unit 2 (MPS2). DNC is proposing to change, add, ordelete the following Technical Specifications:

S

S

TS 1.39 Storage PatternTS 3.9.18 Spent Fuel Pool - Storageo Figure 3.9-1A Minimum Required Fuel Assembly Exposure as a Function of Initial

Nominal Planar Average Enrichment to Permit Storage in Region 2,Type 2A

o Figure 3.9-1 B Minimum Required Fuel Assembly Exposure as a Function of InitialNominal Planar Average Enrichment to Permit Storage in Region 2,Type 2B

o Figure 3.9-1C Minimum Required Fuel Assembly Exposure as a Function of InitialNominal Planar Average Enrichment to Permit Storage in Region 3for Assemblies Containing Borated Stainless Steel Poison Rodlets

o Figure 3.9-1 D Minimum Required Fuel Assembly Exposure as a Function of InitialNominal Planar Average Enrichment to Permit Storage in Region 3for Assemblies Containing a Control Element Assembly

o Figure 3.9-1E Minimum Required Fuel Assembly Exposure as a Function of InitialNominal Planar Average Enrichment to Permit Storage in Region 4

o Figure 3.9-2 Spent Fuel Pool Arrangemento Figure 3.9-3 Minimum Required Fuel Assembly Exposure as a Function of Initial

Nominal Planar Average Enrichment to Permit Storage in Region 3as Consolidated Fuel

o Figure 3.9-4 DELETEDTS 3.9.19 Spent Fuel Pool - Storage PatternTS 5.3.1 Fuel AssembliesTS 5.6.1 CriticalityTS 5.6.3 Capacity.

0

0

0

0

The Bases for TS 3.9.18 and TS 3.9.19 are also being modified to address the proposedchanges and are provided for information only. Changes to the TS Bases are controlled inaccordance with the TS bases control program (TS 6.22).

The proposed changes to the above TS address the following objectives:* Updates spent fuel pool regionalization, which encompasses replacing Regions A, B,

and C with new Regions 1, 2, 3, and 4* Designates certain Region 1, 2, and 4 fuel storage locations as Restricted Locations

which shall not be used to store fuel assemblies, but may be used to store certain non-standard fuel configurations or components, and non-fuel containing components.

* Removes requirements for cell blocking devices.



" Requires that fuel assemblies stored in new Region 3 contain either borated stainlesssteel poison rodlets or a control element assembly (consolidated fuel assembly boxesare excluded from this requirement).

* Removes all reactivity credit for Boraflex.

The proposed changes will allow MPS2 to remove the reactivity credit for Boraflex in thespent fuel racks. In order to meet the spent fuel pool criticality requirements, the followingchanges are being proposed:

" Increasing the number of regions in the spent fuel pool to four.• Selected spent fuel storage rack locations are designated as Restricted Locations in

Regions 1, 2, and 4 (Revised TS Figure 3.9-2). Fuel assemblies shall not be stored inthese locations. Since Restricted Locations will be controlled administratively, cellblocking devices will no longer be required.

" Region 2 has Type 2A and Type 2B storage locations where Type 2A stores higherreactivity fuel than Type 2B.

" The existing enrichment/burnup curves are replaced with five new enrichment/burnupcurves to meet the storage requirements in Regions 2, 3, and 4.

* Fuel assemblies stored in Region 3 must contain either borated stainless steel poisonrodlets or a control element assembly (with the exception of consolidated fuel storageboxes).

" Consolidated fuel storage boxes can only be stored in Region 3.

The changes have been reviewed and confirmed to accommodate fuel currently in thespent fuel pool and a potential future fuel design.



2.0 Detailed Description of Proposed Technical Specifications Changes

Details of the analyses supporting the proposed changes are contained in the criticalitysafety analysis report as provided in Attachment 4 (Proprietary) and Attachment 5 (Non-Proprietary).

2.1 TS 1.39 - Definitions

One definition is being updated to provide additional clarification.

Definition 1.39 - STORAGE PATTERN

Definition 1.39 is updated to clarify that a STORAGE PATTERN is a 2x2 storagearray (encompassing 4 fuel storage rack locations), in which there is at least onelocation in which a fuel assembly is not to be stored. This definition is changed toimprove clarity and to refer to Regions 1, 2, and 4 to which this definition would nowapply.

2.2 TS 3.9.18 - Spent Fuel Pool - Storage

Technical Specification 3.9.18 currently has 3 subparts (a), (b) and (c) which specifyinitial enrichment and burnup requirements for storage of spent fuel in Regions A andC and consolidated fuel storage boxes in Region C. The proposed changes definenew fuel pool storage Regions 1, 2, 3, and 4, replace the existing enrichment/burnupcurves, revise TS Figure 3.9-2 to account for the new regions, and remove TS Figure3.9-4 since Region 1 will not use a burnup curve.

The proposed changes follow:

LCO 3.9.18

Limiting Condition of Operation (LCO) 3.9.18(a), (b), and (c) are removed andreplaced with new LCO 3.9.18(a), (b), (c), (d), and (e). The new items describe theenrichment/burnup requirements (including Region 3 poison insert requirements) tostore fuel assemblies in a given region based on the updated spent fuel pool criticalityanalysis.

Region 1 does not have burnup requirements. Therefore, the fuel assembliesmeeting the TS enrichment requirements can be stored in Region 1. Regions 2, 3,and 4 have enrichment/burnup requirements that must be met to allow storage inthese regions.

Current Region C credits optional installation of three borated stainless steel poisonrodlet inserts. The proposed Region 3, which is composed of all but two of thecurrent Region C fuel storage racks, requires that each fuel assembly contain eitherthree borated stainless steel poison rodlets or a control element assembly



(consolidated fuel storage boxes are excluded from this requirement). A footnote isadded to this TS stating that the full-length, reduced-strength control elementassemblies and the part-length control element assemblies stored in the MPS2 spentfuel racks cannot be used for reactivity control in Region 3.

The enrichment/burnup requirements, poison insert requirements, and RestrictedLocations (described in TS 3.9.18) ensure the following:

* under normal operating conditions Keff will remain < 0.95 with 600 ppm ofsoluble boron in the spent fuel pool, and will remain < 1.0 with 0 ppm ofsoluble boron in the spent fuel pool.

* under postulated misloading or drop accidents Keff will remain < 0.95 with1400 ppm of soluble boron in the spent fuel pool.

The following is a discussion of new and updated figures. The values shown in thesefigures are taken from the criticality safety analysis report.

TS Figure 3.9-1A

TS Figure 3.9-1A is revised. This figure shows the minimum required fuel assemblyburnup as a function of initial nominal planar average enrichment to permit storage offuel assemblies in Region 2 within storage locations designated as Type 2A.

TS Figure 3.9-1B

TS Figure 3.9-1B is revised. This figure shows the minimum required fuel assemblyburnup as a function of initial nominal planar average enrichment to permit storage offuel assemblies in Region 2 within storage locations designated as Type 2B. Region2 Type 2A storage locations can store higher reactivity fuel assemblies than Region 2Type 2B.

TS Figure 3.9-1C

TS Figure 3.9-1C is a new figure. This figure shows the minimum required fuelassembly burnup as a function of initial nominal planar average enrichment to permitstorage of fuel assemblies containing borated stainless steel poison rodlets in Region3.

TS Figure 3.9-1D

TS Figure 3.9-1 D is a new figure. This figure shows the minimum required fuelassembly burnup as a function of initial nominal planar average enrichment to permitstorage of fuel assemblies containing a control element assembly in Region 3.



TS Figure 3.9-1E

TS Figure 3.9-1 E is a new figure. This figure shows the minimum required fuelassembly burnup as a function of initial nominal planar average enrichment to permitstorage of fuel assemblies in Region 4.

TS Figure 3.9-2

TS Figure 3.9-2 is revised. This figure illustrates the new region definitions andstorage patterns of the fuel storage racks. The configuration presented in this figureis based on the criticality safety analysis report.

TS Figure 3.9-3

The Figure 3.9-3 legend and title are revised to conform to the criticality safetyanalysis report. An editorial change is also made to designate the figure as Figure3.9-3 (currently designated as 3.9.3).

TS Figure 3.9-4

This figure is deleted because Region 1 does not have an enrichment/burnup curve.

2.3 TS 3.9.19 - Spent Fuel Pool - Storage Pattern

TS 3.9.19 title is changed from "Storage Pattern" to "Restricted Locations". TS 3.9.19currently has two subparts (1) and (2) which specify requirements for fuel assembliesstored in Region B when cell blocking devices are installed as shown in the currentTS Figure 3.9-2, or when the blocking devices have been removed. The proposedchanges remove requirements for cell blocking devices, but designate that RestrictedLocations shall not be used to store fuel assemblies. Regions 1, 2, and 4 containRestricted Locations in the configuration shown in the revised TS Figure 3.9-2.

The proposed changes are as follows:

The TS title is revised to more clearly describe the updated TS.

LCO 3.9.19

LCO 3.9.19(1) and (2) are replaced with the new LCO which states that fuelassemblies shall not be stored in the Restricted Locations.

The footnotes on this page (Page 3/4 9-26) are removed because the proposedchanges will require that Batch B fuel assemblies conform to the sameenrichment/burnup and poison insert requirements as all other fuel assemblies storedin the fuel pool. The current TS have analyzed and qualified Batch B assemblies forstorage in rack locations containing a cell blocking device. The current analysis does



not apply to the proposed change which removes the requirement for cell blockingdevices, and does not allow storage of any fuel assembly in a Restricted Location.Thus, Batch B must meet the storage requirements of all other fuel assemblies in thepool, and the current footnotes no longer apply.

Surveillance Requirements 4.9.19

The existing surveillance requirement, which verifies that LCO 3.9.19 is satisfied priorto removing cell blocking devices, is changed since the new surveillance requiresverification that LCO 3.9.19 is satisfied through the use of administrative means toassure that a fuel assembly will not be placed into a Restricted Location.

Maintaining the Restricted Locations free of fuel assemblies arid consolidated fuelstorage boxes will ensure that under normal operating conditions Keff will remain <0.95 with 600 ppm of soluble boron in the spent fuel pool, and will remain < 1.0 with 0ppm of soluble boron in the spent fuel pool.

2.4 TS 5.3.1 - Fuel Assemblies

Desigqn Feature 5.3.1

Design Feature 5.3.1 replaces the phrase "nominal average enrichment" with thephrase "initial nominal planar average enrichment" which provides a more precisedefinition as it is treated in the criticality safety analysis report.

2.5 TS 5.6.1 - Criticality

Design Feature 5.6.1

The following changes were made to Design Feature 5.6.1. These changes aresupported with the information provided in the criticality safety analysis report.

* Paragraphs a) and b) - replaces the phrase "nominal average enrichment" withthe phrase "initial nominal planar average enrichment."

* Paragraphs c) and d) - deletes Westinghouse Report A.-MP-FE-001 1,Revision 1 which was not used in the criticality safety analysis report. Thecriticality safety analysis report documents that the reactivity and soluble borondesign requirements are met.

" Paragraph e) - replaces discussion of previous Region A enrichment burnuprequirements with requirements for Region 1. 'Region 1 requirements includecrediting Restricted Locations, specifying a maximum initial nominal planaraverage enrichment requirement of 4.85 weight percent U-235, and that noburnup credit is taken.

" Paragraph f) - replaces discussion of previous Region B enrichment burnuprequirements with requirements for Region 2. Region 2 requirements include



the Type 2A and Type 2B storage locations and that each Type has its ownenrichment/burnup curve.

* Paragraph g) - replaces discussion of previous Region C enrichment burnuprequirements with requirements for Region 3. Region 3 requirements includea requirement that each fuel assembly contain either borated stainless steelpoison rodlets or a control element assembly. There are also twoenrichment/burnup curves for this region, one for fuel assemblies containingborated stainless steel poison rodlets, and one for fuel assemblies containing acontrol element assembly.

" Paragraph h) - replaces Region C with Region 3. All other information is thesame.

" Paragraph i) - new paragraph which discusses Region 4. Informationprovided is similar to the other paragraphs, including center to center distance,Restricted Locations, and its enrichment/burnup curve.

2.6 TS 5.6.3 - Capacity

Design Feature 5.6.3

Design Feature 5.6.3 updates the number of spent fuel pool storage locations(which includes Restricted Locations) for the proposed Regions 1, 2, 3, and 4.

3.0 Discussion

3.1 Introduction

DNC proposes to amend Operating License DPR-65 by incorporating the attachedproposed changes into the TS of MPS2. DNC is proposing to change the followingTechnical Specifications described in Section 1.0 above. The supporting criticalitysafety analysis report is included as Attachment 4 of this submittal.

The proposed amendment implements the following conditions associated with fuelstorage at MPS2:

* Eliminate reactivity credit for Boraflex panels in current regions A and B of thespent fuel pool:

o The proposed change will no longer credit Boraflex as a neutron absorber.The following changes support removal of Boraflex credit.

* Revise alphanumeric designation of spent fuel regions from A, B, C to 1, 2, 3, 4 toclearly distinguish from existing designations:

o Regions 2, 3, and 4 will have new enrichmentlburnup curves. Regions 2 and3 will each have 2 enrichment/burnup curves.

o Region 1 will not have an enrichment/burnup curve. Any fuel assembly in thespent fuel pool can be stored in Region 1.



Page 10 of 20

" Revise allowed storage patterns for fuel assemblies in the spent fuel pool to meetKeff requirements under normal and accident conditions:

o Certain locations will no longer be allowed to store fuel assemblies (proposedTS Figure 3.9-2). Region 1 will only allow fuel assembly storage in a 2 out of4 storage pattern, and Regions 2 and 4 will allow a 3 out of 4 storage pattern.Region 3 can store fuel assemblies in any location.

o Only Region 3 has every storage location available.o Only Region 3 will be able to store consolidated fuel storage boxes.

" Allow use of control element assemblies as well as borated stainless steel poisonrodlets in Region 3:

o Fuel assemblies stored in Region 3 would be required to contain boratedstainless steel poison rodlets or a control element assembly.

o Consolidated fuel storage boxes are exempted from containing boratedstainless steel poison rodlets or a control element assembly.

" Eliminate requirement to use spent fuel rack cell blocking devices:o Regions 1, 2, and 4 will have storage rack locations that will not be permitted

to store fuel assemblies (proposed TS Figure 3.9-2).

3.2 Current MPS2 Spent Fuel Pool Configuration

The MPS2 spent fuel pool currently consists of three regions of spent fuel storageracks, designated Regions A, B and C. TS Figure 3.9-2 provides a schematic of thepool layout. The Region A and B racks contain Boraflex as the active neutronabsorber in a flux trap design. The Region C racks have an egg crate design with nofixed neutron absorber. Fuel may be stored in three types of configurations in RegionC per current TS. Fuel assemblies stored in Region C may be stored with or withoutborated stainless steel poison rodlets (for reactivity control), and consolidated fuelstorage boxes are also allowed to be stored in Region C. The consolidated fuelstorage box has essentially the same dimensional envelope as a fuel assembly.Forty Region B fuel storage locations contain certain low reactivity fuel assembliesunderneath cell blocking devices for added reactivity control.

Soluble boron is currently credited in the spent fuel pool for reactivity control for bothnormal and accident conditions.

The maximum initial nominal planar average enrichment used is the currentlylicensed value of 4.85 weight percent U-235.



Page 11 of 20

4.0 Technical Evaluation Summary

4.1 Introduction

The analyses and results summarized in this section are provided in the criticalitysafety analysis report. DNC addressed the following issues as the most significanttechnical considerations for the proposed changes.

Use of the cell blocking devices will no longer be required. Fuel storage loadingrequirements will continue to be maintained by administrative means. Cell blockingdevices are not considered to be a sufficient barrier to preclude a fuel misloadaccident, as they are not permanent. The consequences of such an accident are thesame, whether or not a cell blocker is present. The MPS2 spent fuel pool has beenanalyzed to accommodate a single misload or drop of the highest enrichment freshfuel assembly in any region as well as multiple assembly misloads along theboundary between regions.

Since a spent fuel pool soluble boron concentration of 600 ppm is credited forreactivity control under normal conditions, assurance must be provided that a spentfuel pool soluble boron dilution event will not cause spent fuel pool boronconcentration to be decreased from the LCO minimum value of > 1720 ppm, to < 600ppm.

These proposed design changes do not result in any hardware changes to the plant.The cell blocking devices are already of a removable design and not an integral partof the storage racks. There are no changes in how the borated stainless steel poisonrodlets are used in Region 3 of the spent fuel pool, or how control elementassemblies are placed and stored in fuel assemblies. There are no changes in howfuel is moved, or the process used to qualify and verify fuel storage in the pool otherthan the updated enrichment/burnup curves and not placing fuel assemblies inRestricted Locations in the fuel pool.

From an operational perspective, the proposed design changes are transparent.Spent fuel pool soluble boron concentration requirements will riot change. Theproposed changes take a partial reactivity credit for the soluble boron currently inplace. The changes in enrichment/burnup values lead to the proposed TS Figures3.9-1A through 3.9-1 E and the deletion of Figure 3.9-4. However, there are nochanges in how fuel is moved, or in any method of how administrative means areused to ensure that fuel is not misloaded.

4.2 Spent Fuel Pool Criticality Analysis - General

The criticality safety analysis report to support the proposed changes was performedby DNC.



Page 12 of 20

The criticality analysis has been conservatively performed by riot crediting anyintegral fuel burnable absorbers, which typically exist in fresh fuel. The most reactivefuel design is used for each storage region, and the most reactive spent fuel poolwater temperature is considered for each region. A tolerance and uncertaintyanalysis is also provided.

Fuel assemblies used at MPS2 may include reduced enrichment fuel rods adjacent toguide thimbles and reduced enrichment axial blanket regions. For simplicity, theMPS2 criticality calculations are performed using a single enrichment in all fuel rodsthat is the highest initial planar average U-235 enrichment of the axial regions in thefuel assembly. This averaged enrichment is designated as the initial nominal planaraverage enrichment.

4.3 Spent Fuel Pool Criticality Analysis - Normal Storage Conditions

Region 1 of the spent fuel storage pool is designed to ensure a Keff< 0.95 with thespent fuel pool filled with water borated to a minimum concentration of 600 ppm fornormal conditions. Fresh fuel assemblies stored in this region may have a maximuminitial nominal planar average enrichment of 4.85 wt % U-235. This region, whichcontains Restricted Locations, stores fuel assemblies in a 2 out of 4 configuration forreactivity control, as shown in proposed TS Figure 3.9-2.

Region 2 of the spent fuel storage pool is designed to ensure a Keff < 0.95 with thestorage pool filled with water borated to a minimum concentration of 600 ppm fornormal conditions. Region 2 contains two types of storage locations, Type 2A (higherreactivity) and Type 2B (lower reactivity), as shown in TS Figure 3.9-2. Fuelassemblies stored in this region must comply with Figure 3.9-1A (Type 2A locations)or Figure 3.9-1 B (Type 2B locations) to be in the acceptable burnup domain. Thisregion, which contains Restricted Locations, stores fuel assemblies in a 3 out of 4configuration for reactivity control, as shown in proposed TS Figure 3.9-2.

Region 3 of the spent fuel storage pool is designed to ensure a Keff < 0.95 with thestorage pool filled with water borated to a minimum concentration of 600 ppm fornormal conditions. Fuel assemblies stored in Region 3 must contain either boratedstainless steel poison rodlets or a control element assembly, except for the full-length,reduced-strength and the part length control element assemblies existing in the fuelpool racks (see proposed change to TS 3.9.18, including its Basis). Fuel assembliesstored in this region must comply with Figure 3.9-1C (containing rodlets) or Figure3.9-1D (containing a control element assembly) to be in the acceptable burnupdomain. Only Region 3 can store consolidated fuel storage boxes (which do not needrodlets or a control element assembly). However, consolidated fuel storage boxesmust comply with Figure 3.9-3 to be in the acceptable burnup domain. This regiondoes not contain Restricted Locations.

Region 4 of the spent fuel storage pool is designed to ensure a Keff < 0.95 with thestorage pool filled with water borated to a minimum concentration of 600 ppm for



Page 13 of 20

normal conditions. Fuel assemblies stored in this region must comply with Figure3.9-1E to be in the acceptable burnup domain. This region, which contains RestrictedLocations, stores fuel assemblies in a 3 out of 4 configuration for reactivity control, asshown in proposed TS Figure 3.9-2.

Note that there are non-standard fuel configurations and components, and non-fuelcontaining components present in the spent fuel storage racks. These non-standardfuel configurations and components, and non-fuel containing components may bestored in fuel assembly locations if they are demonstrated to be non-limiting withrespect to the fuel assemblies that have been analyzed. The same methodologyused for the analysis that established the TS requirements will be employed toevaluate non-standard fuel configurations and components, and non-fuel containingcomponents. These non-standard fuel configurations and components, and non-fuelcontaining components may also be stored in fuel storage rack locations designatedas a Restricted Location following an evaluation utilizing the same analysismethodology employed to establish the requirements of this TS.

The above analyses show that, for all Regions of the SFP, 600 ppm of soluble boronis needed under normal conditions to assure that the spent fuel pool Keff is less thanor equal to 0.95 (including biases and uncertainties). Also, the criticality analysisshows that even with 0 ppm of soluble boron, under normal conditions the spent fuelpool Keff is less than 1.00 (including biases and uncertainties).

4.4 Spent Fuel Pool Criticality Analysis - Accident Conditiions

The spent fuel pool criticality analysis has analyzed the postulated accidentconditions listed below. Although some evaluations in the criticality analysis providedin Attachment 4 are performed with fuel having 5.0 wt % U-235 initial nominal planaraverage enrichment, the current TS limit of 4.85 wt % is not being changed. Thus,the accident analysis in the criticality safety analysis report bounds the proposedchange.

" Misplacement or dropping of a single fresh fuel assembly, with a 5.0 wt % nominalplanar average enrichment, into a Region 1, 2, 3, or 4 storage location.

* Temperature reaches boiling conditions which increases reactivity in Regions 3 and4 of the SFP.

" Dropping of a fuel assembly on top of a fuel storage rack which comes to rest in ahorizontal or vertical position.

" Misplacement of a fresh fuel assembly, with a 5.0 wt % nominal planar averageenrichment, between Region 3 and the new fuel elevator, with a 5.0 wt % fresh fuelassembly in the new fuel elevator.



Page 14 of 20

Incorrect fuel assembly placement in which the boundaries between the differentregions of the MPS2 fuel-storage racks are out of alignment in such a way thatmaximizes the reactivity.

For these accident conditions, credit for soluble boron is acceptable per the doublecontingency principle to ensure that Keff is < 0.95, including uncertainties and biases.

Based on the criticality safety analysis report, the limiting accident is a misloaded fuelassembly. The total amount of soluble boron required is the 800 ppm to compensatefor the reactivity increase from the misloaded fuel assembly, plus 600 ppm for normalconditions, for a total of 1400 ppm.

The current TS requires a minimum concentration of 1720 ppm soluble boron at all

times that fuel is in the spent fuel pool.

4.5 Boron Dilution Analysis

A soluble boron dilution analysis of potential scenarios which could dilute the boronconcentration in the SFP demonstrates that sufficient time is available to detect andmitigate a boron dilution prior to reaching the minimum soluble boron required undernormal conditions, thus ensuring that Keff 5 0.95 (including biases and uncertainties).The existing SFP boron dilution analysis established the current SFP minimum TS3.9.17 soluble boron limit of 1720 ppm. The existing SFP criticality analysis alsorequires a minimum of 600 ppm under normal operating conditions in the SFP toensure that Keff meets the design basis requirement. For accident conditions, theexisting analysis credited up to 1400 ppm soluble boron in the criticality analysis. Therevised criticality analysis has confirmed that a minimum of 600 ppm of soluble boronis sufficient to maintain Keff < 0.95 under normal conditions and that 1400 ppm ofsoluble boron is sufficient to maintain Keff < 0.95 for postulated accident conditions.

The potential dilution sources described in the existing analysis are not crediblethreats to the SFP soluble boron concentration from 1720 ppm to 600 ppm due toeither volume or flow rate considerations. The large volume of water required todilute the SFP, the TS controls on SFP boron concentration, observation during plantoperator rounds as well as engineered alarms, would effectively detect a dilutionevent prior to Keff reaching 0.95. These considerations and mitigation measuresremain unchanged for the revised criticality analysis. As discussed in Attachment 4,the 600 ppm and 1400 ppm values for normal and accident conditions, respectively,are retained for this analysis. The existing dilution volumes, flow rates, and eventmitigation response times remain unchanged for this analysis. The existing borondilution analysis conclusions remain applicable and unchanged and the proposedchange continues to meet the criticality requirements with the current TS minimumsoluble boron.

4.6 Boraflex Material Monitoring



Page 15 of 20

Region 1 and 2 spent fuel racks contain Boraflex which will no longer be credited as aneutron absorber. Therefore, the Boraflex monitoring program will be discontinued.

4.7 Decreased Fuel Storage

The proposed change decreases the number of fuel assemblies that can be stored inthe fuel pool due to its implementation of Restricted Locations (there are a greaternumber of proposed Restricted Locations than current cell blocker locations). Sincethe spent fuel pool will be licensed to store fewer assemblies, the current mechanicaland seismic analyses, as well as the current design basis heat load analysis, remainbounding.

4.8 Implementation Considerations

Following NRC approval of the proposed change, DNC will offload a number of spentfuel assemblies into dry storage to clear adequate fuel storage locations. Up to 7canisters will be loaded and transferred to the Millstone Power Station IndependentSpent Fuel Storage Installation (ISFSI). After this campaign is complete, DNC willrearrange fuel in the spent fuel pool so that each fuel assembly will be in compliancewith the new spent fuel pool storage configuration and enrichment/burnup curves.

Given the planning and effort needed to perform these fuel storage campaigns, andthe uncertainties with projecting a schedule for these complex evolutions more thantwo years in advance, DNC will complete this work and fully implement the revisedTS by September 1, 2015.

4.9 Conclusions

Implementation of the proposed changes is safe and will have no effect on currentplant operation. There are no hardware changes made to the plant due to theseproposed changes. There are no changes in how fuel is handled, or the processused to qualify and verify fuel storage in the pool.

The cell blocking devices are removable, and can be removed from the spent fuelracks. Fuel storage loading requirements will continue to be maintained byadministrative means. Cell blocking devices are not considered to be a sufficientbarrier to preclude a fuel misload accident, as they are not permanent. Theconsequences of such an accident are the same, whether or not a cell blockingdevice is present. The MPS2 spent fuel pool has been analyzed to accommodate asingle misload of the highest enrichment fresh fuel assembly in any region as well asmultiple assembly misloads along the boundary between regions.

The spent fuel pool criticality analysis to support the proposed modifications usesstandard criticality analysis methods. MPS2 continues to maintain the spent fuel poolsoluble boron concentration > 1720 ppm. Potential boron dilution events have beenpreviously reviewed, and the review has shown that it is not credible that the spent



Page 16 of 20

fuel pool soluble boron concentration can be reduced from > 1720 ppm to < 600 ppmbecause there is sufficient time available to detect and mitigate a boron dilution event.The spent fuel racks were designed from a structural perspective for storage of fuel inall rack locations, and the current design basis heat load analysis already bounds theproposed reduction in fuel storage capacity.

The proposed criticality analysis no longer credits Boraflex for neutron absorption.Thus, it is no longer necessary to continue the Boraflex monitoring program.

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 andHandling," states that "criticality in the fuel storage and handling system shall beprevented by physical systems or processes, preferably by use of geometrically safeconfigurations." The NRC has established a 5% subcriticality margin (i.e., Keff < 0.95)for nuclear power plant licensees to comply with GDC 62.

10 CFR 50.68, "Criticality Accident Requirements," states in subpart (b)(4) that "ifcredit is taken for soluble boron, the Keff of the spent fuel storage racks loaded withfuel of the maximum fuel assembly reactivity must not exceed 0.95, at a 95 percentprobability, 95 percent confidence level, if flooded with borated water, and the Keffmust remain below 1.0 (subcritical), at a 95 percent probability, 95 percent confidencelevel, if flooded with unborated water."

5.2 No Significant Hazards Consideration

DNC has evaluated whether or not a significant hazards consideration is involvedwith the proposed amendment by addressing the three standards set forth in 10 CFR50.92, "Issuance of Amendment," as discussed below: I

1. Does the proposed change involve a significant increase in the probability or

consequences of an accident previously evaluated?

Response: No.

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

The proposed change will not affect the physical plant, including the spentfuel pool, spent fuel racks, or fuel handling equipment. While there will bemore regions to consider in the spent fuel pool, the process of choosing fuelassembly locations will not change other than the regionalization and burnupcurves will be revised. Also, the process of handling fuel assemblies will not



Page 17 of 20

change. The Millstone Power Station Unit 2 (MPS2) program for choosingfuel assembly storage locations, and for fuel handling and assuring that thefuel assemblies are placed into correct locations will remain in place. Thesuccess of this program in preventing misloading and dropping of a fuelassembly has been historically demonstrated. Thus, the probability of a fuelassembly misloading or a fuel assembly drop will not significantly increasewith the proposed change.

Multiple postulated accidents were reviewed for the proposed change whichincluded several fuel misloading scenarios and a fuel assembly drop.

The criticality analysis concluded that the limiting accident is a misloadedfresh fuel assembly. The analysis also concluded that this accident requiresan additional 800 ppm of soluble boron. The total amount of soluble boronrequired is the 800 ppm to compensate for the reactivity increase from thefuel assembly misload, plus 600 ppm for normal conditions, for a total of1400 ppm, which is the same conclusion as the current analysis. The currenttechnical specifications (TS) require a minimum concentration of 1720 ppmsoluble boron at all times that fuel is in the spent fuel pool. The proposed TSwill maintain this soluble boron requirement.

A boron dilution accident was reviewed. There are no changes to the plant,plant equipment or operations required by the proposed change. Also, thecriticality analysis concluded that the current soluble boron requirement (>1720 ppm) bounds the consequences associated with the proposed change.Thus, there is no change to consequences of a boron dilution accident.

In the case of each accident, Keff continues to be less than the licensing limitof 0.95. Thus, it is concluded that the consequences of a previouslyevaluated accident remains that same.

Since the proposed change reduces the number of fuel assemblies that canbe stored in the fuel storage racks, the current seismic/structural and heatload analyses bound the proposed change.

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 differentkind of accident from any accident previously evaluated.

There is no change to the physical plant, including the equipment andprocedures used to handle fuel (or any heavy load) over fuel storage racks,or how the fuel assemblies are stored in the storage racks. Thus, there are



Page 18 of 20

no new accidents created over and above the existing postulated accidentsof a fuel misload or a fuel assembly drop onto the racks.

Use of cell blocking devices will no longer be required. The cell blockingdevices are removable, and can be removed from the spent fuel racks. Fuelstorage loading requirements will continue to be maintained by administrativemeans. Cell blocking devices are not considered to be a sufficient barrier topreclude a fuel misload accident, as they are not permanent. Theconsequences of such an accident are the same, whether or not a cellblocker is present. The MPS2 spent fuel pool has been analyzed toaccommodate a single misload of the highest enrichment fresh fuel assemblyin any region as well as multiple assembly misloads along the boundarybetween regions. Thus, removing the requirement to use cell blockingdevices will not create a new accident over and above the existing postulatedaccidents of a fuel misload or a fuel assembly drop onto the racks.Reducing the number of fuel assemblies that can be stored in the fuelstorage racks will not create any new or different type of accident.

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 ofsafety

The licensing requirement for the spent fuel pool is that Keff remain less thanor equal to 0.95 under all postulated accident conditions (misloaded ordropped fuel assembly, and boron dilution). These accidents were analyzedfor the proposed change, and the Keff < 0.95 requirement is met in all cases.In addition, the criticality analysis concluded that, under normal conditions,the fuel pool Keff will remain less than 1.0 with 0 ppm boron in the pool.

Since the proposed change reduces the number of fuel assemblies that canbe stored in the fuel storage racks, the current seismic/structural and heatload analyses' margin of safety bound the proposed change.

Based on the above information, DNC concludes that the proposed licenseamendment involves no significant hazards consideration under the criteria setforth in 10 CFR 50.92(c) and, accordingly, a finding of no significant hazardsconsideration is justified.



Page 19 of 20

5.3 Precedents

The proposed changes to the MPS2 technical specifications are similar infundamental aspects to the following proposed changes that have been submitted toreflect results of spent fuel criticality analyses:

1. Kirwin, Thomas P, "Palisades License Amendment Request for Spent Fuel PoolRegion I Criticality," Letter to Document Control Desk, NRC, from Acting Site VicePresident, January 31, 2011 (ADAMS Accession No. ML1 10380083).

2. Mahesh L. Chawla of the NRC, "Pallisades Nuclear plant - Issuance ofAmendment Re: Spent Fuel Pool Region I Criticality," letter from NRC to VicePresident, Operations Entergy Nuclear Operations, Inc., January 27, 2012(ADAMS Accession No. ML1 1362A468)

3. Kiley, Micheal, "Turkey Point Units 3 and 4 License Amendment Request No. 207,Fuel Storage Criticality Analysis," Letter to Document Control Desk, NRC, fromActing Site Vice President, August 5, 2010 (ADAMS Accession No. ML10220022)

4. Jason C. Paige, "Turkey Point Nuclear Plant, Units 3 and 4 - Issuance ofAmendments Regarding Fuel Criticality Analysis," letter to from NRC to ExecutiveVice President and Chief Nuclear Officer, Florida Power and Light CompanyOctober 31, 2011 (ML11216A057)

The current MPS2 application includes unique aspects that reflect DNC'sunderstanding of NRC staff expectations for spent fuel submittal content andsupporting analyses. The submittal content was developed based on insights anddiscussion between DNC and NRC staff which occurred at two pre-submittalmeetings:

1. Summary of February 15, 2012, Pre-Application Meeting with Dominion NuclearConnecticut, Inc., to discuss a Proposed Millstone Power Station, Unit 2, LicenseAmendment Request Concerning Spent Fuel Pool Criticality Re-Analysis, March12, 2012 (ML120580362)

2. Forth Coming Pre-Application Meeting with Dominion Nuclear Connecticut, Inc., toDiscuss a Proposed Millstone Power Station, Unit 2, License AmendmentRequest Concerning Spent Fuel Pool Criticality Re-Analysis, June 27, 2012(ML2178A613)

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,



Page 20 of 20

and (3) the issuance of the requested license amendments will not be inimical to thecommon defense and security or to the health and safety of the public.

6.0 Environmental Considerations

DNC has reviewed the proposed license amendment for environmental considerations.The proposed license amendment does not involve (i) a significant hazards consideration,(ii) a significant change in the types or significant increase in the amounts of any effluentthat may be released offsite, or (iii) a significant increase in individual or cumulativeoccupational radiation exposure. Accordingly, the proposed amendment meets theeligibility criterion for categorical exclusion from an environmental assessment as set forthin 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impactstatement or environmental assessment need be prepared in connection with theproposed amendment.

7.0 References

1. NRC Interim Staff Guidance DSS-ISG-2010-01, Revision 0, "Staff GuidanceRegarding the Nuclear Criticality Safety Analysis for Spent Nuclear Fuel Pools",9/29/2011.

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


Attachment 2

Marked-up Technical Specifications Pages


-. ptem•b, r 20, 2001INDEX

LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS

SECTION PAGE

3/4.9 REFUELING OPERATIONS

3/4.9.1 BORON CONCENTRATION ....................................................................... 3/4 9-1

3/4.9.2 IN STRU M EN TATION .................................................................................. 3/4 9-2

3/4.9.3 D E C A Y T IM E ................................................................................................ 3/4 9-3

3/4.9.4 CONTAINMENT PENETRATIONS ........................................................... 3/4 9-4

3/4.9.5 D E L E T E D ..................................................................................................... 3/4 9-5

3/4.9.6 D E L E T E D ..................................................................................................... 3/4 9-6

3/4.9.7 D E L E T E D ...................................................................................................... 3/4 9-7

3/4.9.8 SHUTDOWN COOLING AND COOLANT CIRCULATION .................... 3/4 9-8

H igh W ater L evel ........................................................................................... 3/4 9-8

L ow W ater L evel .......................................................................................... 3/4 9-8b

3/4.9.9 D E L E T E D ...................................................................................................... 3/4 9-9

3/4.9.10 D E L E T E D .................................................................................................... 3/4 9-10

3/4.9.11 WATER LEVEL - REACTOR VESSEL ..................................................... 3/49-11

3/4.9.12 STORAGE POOL WATER LEVEL ............................................................ 3/4 9-12

3/4.9.13 D E L E T E D .................................................................................................... 3/4 9-13

3/4.9.14 D E L E T E D .................................................................................................... 3/4 9-14

3/4.9.15 D E L E T E D .................................................................................................... 3/4 9-16 4-3/4.9.16 SH IELD ED CA SK ...................................................................................... 3/4 9-19

3/4.9.17 SPENT FUEL POOL BORON CONCENTRATION .................................. 3/4 9-21

3/4.9.18 SPENT FUEL POOL - STORAGE ............................................................. 3/4 9-22

3/4.9.19 SPENT FUEL POOL - STORP,AGE PATTEP64 ........................................... 3/4 9-26

3/4.9.20 SPENT FUEL POOL - CONSOLIDATION ...................... 3/4 9-27

3/4.10 SPECIAL TEST EXCEPTIONS [RESTRICTED LOCATIONS

3/4.10.1 SHU TD O W N M A RG IN ............................................................................. 3/4 10-1

3/4.10.2 GROUP HEIGHT AND INSERTION LIMITS ......................................... 3/4 10-2

3/4.10.3 D E L E T E D .................................................................................................... 3/4 10-3

MILLSTONE - UNIT 2 IX Amendment No. 69, 4-04, 409, +4--7,4-5-3, 4--5-8, 240, 24-5, -249, 2-74, 280, 284,

March 16, 2006DEFINITIONS

VENTING

1.35 VENTING is the controlled process of discharging air or gas from a confinement tomaintain temperature, pressure, humidity, concentration or other operating condition, in such amanner that replacement air or gas is not provided or required during VENTING. Vent, used insystem names, does not imply a VENTING process.

MEMBER(S) OF THE PUBLIC

1.36 MEMBER(S) OF THE PUBLIC shall include all persons who are not occupationallyassociated with the plant. This category does not include employees of the utility, its contractorsor its vendors. Also excluded from this category are persons who enter the site to serviceequipment or to make deliveries. This category does include persons who use portions of the sitefor recreational, occupational or other purposes not associated with the plant.

The term "REAL MEMBER OF THE PUBLIC" means an individual who is exposed to existingdose pathways at one particular location.

SITE BOUNDARY

1.37 The SITE BOUNDARY shall be that line beyond which the land is not owned, leased orotherwise controlled by the licensee.

UNRESTRICTED AREA

1.38 An UNRESTRICTED AREA shall be any area at or beyond the SITE BOUNDARY towhich access is not controlled by the licensee for purposes of protection of individuals fromexposure to radiation and radioactive materials or any area within the SITE BOUNDARY usedfor residential quarters or industrial, commercial institutional and/or recreational purposes.

STORAGE PATTERN

a&mini..tra:ive . .ntr.l. This 4th l..ation will be .. fc-r•d to as the bd L .... dAS CTORAGEFPATTERN fefcr-s to a blockcd location and all adjaeent and diagenal eel! leeations surrounditig

X1'

T e E)e Ee Ovat OR " r H r e repe* e r-etI lq"

replace with Insert T. 1

MILLSTONE - UNIT 2 1-8 Amendment No. 4-04, 44-7, -4-5-5, 4-72,29,

Insert T.1 to TS 1.39

1.39 A STORAGE PATTERN designates acceptable fuel assembly storage in a 2 x 2storage array (4 spent fuel rack storage locations) within Regions 1, 2, and 4 of thespent fuel racks. Each 2 x 2 storage array includes at least one location in which a fuelassembly is not to be stored.

April 1, 00;Garee e LcG ntter dated -2 26 014

REFUELING OPERATIONS

SPENT FUEL POOL - STORAGE /"LIMITING CONDITION FOR OPE-RATION

3.9.18 The following spent fuel pool storage requirement will be met:

0kt) The combination of initial enriehmcint and burnmup of caeh fuci assembly storedin Region A shall becwithin the accoptabic burnHup dtmin of Figure 3.9 4I; and

//

Replace withInsert T.2

I I I I I I I

tnti eamcinwatin at tnttat etnrietiment an u poramiaJm1starced on Region C shall bo within the accpal bumup domainofigr

The combination f i•nitifal cnrichmcnt and burnup of 4-11Al ntatr-Id int Region C sha!! be within the a...ptabl. bu Iup domain of Figure

3.9 11B, and berated stainless steel poiso pin arc istal&1ed in theassenibly's eenter guide tube and in two diagontally apposite -guide tubes;

//

.Inominal planar averageI

> (-e-) The combination of initial Aerichment and burnup of each consolidated fuelstorage box stored in Region within the acceptable burnup domainof Figure 3.9-3. w

APPLICABILITY: Whenever any fuel assembly or consolidated fuel storage box is stored inthe spent fuel pool.

ACTION:

Immediately initiate action to move the non-complying fuel assembly or consolidated fuel storagebox to an acceptable location.

The provisions of specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS

Inominal planar averageI

/

//

/

4.9.18 Prior to storing a fuel assembly or c*solidated fuel storage box in the spent fuelracks, verify by administrative means the initial enrichment and burnup of the fuel assembly orconsolidated fuel storage box is in accordance with the acceptable specifications for that StorageRegion.

/MILLSTONE - UNIT 2 3/4 9-22 Amendment No. 4-09, 44-7, 4-5-3, 4-5-8,S 11 '7/1 )'7A

* Full-length, reduced-strength control element assemblies and part-length control

element assemblies are not to be used in Region 3.

Insert T.2 to TS 3.9.18

(a) Region 1 fuel assemblies have a maximum initial nominal planar averageenrichment of 4.85 weight percent of U-235. A fuel rod shall have a maximumenrichment of 5.0 weight percent of U-235. No burnup credit is required.

(b) Region 2 has two types of storage locations:(1) The combination of initial nominal planar average enrichment and burnup of a

fuel assembly stored in Region 2 Type 2A shall be within the acceptableburnup domain of Figure 3.9-1A.

(2) The combination of initial nominal planar average enrichment and burnup of afuel assembly stored in Region 2 Type 2B shall be within the acceptableburnup domain of Figure 3.9-1 B.

(c) Fuel assemblies stored in Region 3 shall contain either borated stainless steelpoison rodlets, or a control element assembly:(1) The combination of initial nominal planar average enrichment and burnup of a

fuel assembly containing borated stainless steel poison rodlets stored inRegion 3 shall be within the acceptable burnup domain of Figure 3.9-1C. Theborated stainless steel poison rodlets shall be installed in the assembly'scenter guide tube and in two diagonally opposite guide tubes.

(2) The combination of initial nominal planar average enrichment and burnup of afuel assembly containing control element assemblies stored in Region 3 shallbe within the acceptable burnup domain of Figure 3.9-1 D.

(d) The combination of initial nominal planar average enrichment and burnup of afuel assembly stored in Region 4 shall be within the acceptable burnup domain ofFigure 3.9-1 E.

Appil 1,2003

IReplace with Figure 3.9-lA]

I160

40

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-- -T -__01.85 2.35 2.85 3.35 3.85 4.35 4.85

BLY INITIAL ENRICHMENT, W O

N OF INITIAL ENRICHMENT TO PERMIT STORAGE 1TI-•

MILLSTONE - UNIT 2 • 3/4 9-23 Amendment No. +-7-, 4--7, 448, --72,•2-74,

20. . ...Ii 4

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... ..... . ... . ..

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! -- 1 ........."i" Enrich Burnup

4.21 10

0 d i I ... .. _.. .. _2.50 3.00 3.50 4.00 4.50 5.00

Fuel Assembly Initial Nominal Planar Average Enrichment, Wt% U-235

Figure 3.9-1A Minimum Required Fuel Assembly Exposure as a Function of Initial Nominal PlanarAverage Enrichment to Permit Storage in Region 2, Type 2A

MILLSTONE - UNIT 2 3/49-23 Amendment No. 4299, 44-7-, -57, 474,

2-74,

April 1, 2003.

45

40

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MILLSTONE - UNIT 2 3/4 9-23a Amendment No. 4-7-2, 2-7-4,

40

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Figure 3.9-1 B Minimum Required Fuel Assembly Exposure as a Function of Initial Nominal PlanarAverage Enrichment to Permit Storage in Region 2, Type 2B

MILLSTONE -UNIT 2 3/4 9-23a Amendment No.--72, 2-74,

60 _

.. .......... ............ ...... ............... .... ..................... ..50 __

.. . . .... .... ... .. .. .. . . . ... .....

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........................ .... ........ 4. 8 5

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Figure 3.9-1 C Minimum Required Fuel Assembly Exposure as a Function of Initial Nominal PlanarAverage Enrichment to Permit Storage in Region 3 for Assemblies Containing Borated Stainless

Steel Poison Rodlets

MILLSTONE -UNIT 2 3/4 9-23b Amendment No.

40

30 -- It - Alf _ - -- -

0

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_L ACCEPTABLE 4---- ---- --

2 0 i ...... .............

taJ• i t ............... ...... . .... .. .. ........ ...... ............

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0 4_ _/__ ______ __ __

2.00 2.50 3.00 3.50 4.00 4.50 5.00


Figure 3.9-1 D Minimum Required Fuel Assembly Exposure as a Function of Initial Nominal PlanarAverage Enrichment to Permit Storage in Region 3 for Assemblies Containing a Control Element

Assembly

MILLSTONE -UNIT 2 3/4 9-23c Amendment No.

50

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1.50 2.00 2.50 3.00 3.50 4.00 4.50 5.00


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I..131 3313131313 3 3 3 3 3 3 3 3 3 3 3 3 T 1

- 36-r34-

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• 24-ACCEPTABLE FOR

22 STORAGE IN REGION e

z 20

CD 18-

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• 14-> 12">< 12 UNACCEPTA EF

>" 10-STORAGE IN R GION G

8 8-Luun 6U,'*: 4

4-W 2

> L.0-

1.0 1.5 2.0 2.5 3.0 3.5 4.0 45 5.0

FUEL ASSEMBLY INITIAL ENRICHMENT, WT.% U- 35

FIGURE 43--.3. MINIMUM REQUIRED FUEL ASS BLY EXPOSURE AS A UNCTION OFINITIAL RICHMENT TO PERMIT ORAGE IN REGION G AS 4,

-'",--JMC"TSllKRAW I DI AKlAI AVI :IF/. V -

I

IDelete and replace with "THIS PAGE INTENTIONALLY LEFT BLANK" I ApiI-, , 200,

7

6

5

Z

LTJ

C,'

4

3

2

1

ACCEPTABLE

/CH /BURNUP3.04.8, 5 6. 83 5

I I I I /1'.I I I I II I I I I I I I I I I IA d

0 -3.35 3.6 3.85 4.1 4.35 4.6 4.85

,EMILY INITIAL ENRICHMENT 0 __

FIGURE 3.9-4 MINIMU OSURE AS A FUNCTION

MILLSTONE - UNIT 2 3/4 9-25a Amendment No. 4-5-9, 2-74,

April 1,200REFUELING OPERATIONS 'RESTRICTED LOCATIONS

SPENT FUEL POOL - STORAGE PATTEP

LIMITING CONDITION FOR OPERATION

3).9.19 Eaeh STORAGE PATTERN afthc Region 3 spent fuci pool faeks shall rcgquirc that-

64- A ee! blockfing dcvicc is itistalled in these eel! loeations Thownq in Figurce3.9 2. The bleekd laeatiat may sterc - Ba-tch B3 fu~le.~~4underneath the teeli lok; or

(2.4 if a eel! blockeing deviee has been refmoPATTERN, &eeept the location with theffust be ;vaeant of stored fuciea. mbi

APPLICABILITY: Fuel in the spent fuel poo*

ACTION: Welete

Take immediate action to comply with either 3.9.19(i.• - (2)

The provisions of specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS

Hedp-all-ells in th0 STOsertT.r-efiedMI bleekitng d-, it

Replceiwith Insert TA441"

4.9.19 Vcrify that ;.9.19 is satisfid prior- t -egl cl blockting dcv~icc

replace with Insert T.5I

n* A Restricted Location may contain non-standard fuel configurations or

icomponents, or is empty.

A Batch B fucel assembly r-fcrs to any *the Batch B fucie asseffices which were pat4 ethe first Millstone 2 corce.

This , LC: is not appli:abl. u"ring the initial installation of Batch B fucl assemblies in the.eli blckcr leeations.

MILLSTONE - UNIT 2 3/4 9-26 Amendment No. 44-7, -5-3, 4-548, 4-7-2,274,


Fuel assemblies shall not be stored in a spent fuel pool rack Restricted Location(shown in Figure 3.9-2).


Prior to storing a fuel assembly in the spent fuel racks, verify by administrative meansthat it will not be placed in a Restricted Location (as shown in Figure 3.9-2).

DESIGN FEATURES

5.3 REACTOR CORE

FUEL ASSEMBLIES initial nominal planar

5.3.1 The reactor core shallr n 217 fuel assemblies with each fuel assembly containing176 rods. Reload fbe similar in physical design to the initial core loading and shall havea maximum average enrichment of 4.85 weight percent of U-235. A fuel rod shall have a -Maximu enrichment of 5.0 weight percent of U-235.

initialCONTROL ELEMENT ASSEMBLIES

5.3.2 The reactor core shall contain 73 control element assemblies. The control elementassemblies shall be designed and maintained in accordance with the design provisions containedin Section 3.0 of the FSAR with allowance for normal degradation pursuant to the applicableSurveillance Requirements.

5.4 DELETED

MILLSTONE - UNIT 2 5-4 Amendment No. -3-, 4-4-9, 446, 2-04,24-6, 2--0, 2-7,4, 280, 29g-,

DESIGN FEATURES

5.5 DELETED

5.6 FUEL STORAGE

CRITICALITY

5.6.1 a) The new fuel (dry) storage racks are desig and shall be maintained with s ficientcenter to center distance between assemblies tnsure a Keff _< .95. The maximum ie fflinalaverage fuel assembly enrichment to besed in these racks is 4.85 weight percent U-235. Themaximu uel rod enrichment to bered in these racks is 5.0 weight percent of U-235.

b) The spent fuel ge racks are designed and shall be maintained with fuel assemblies

having a maximum ntief4n average enrichment of 4.85 weight percent U-235. The maximumfuel rod enrichment to. be stored in these racks is 5.0 weight percent U-23 5.

c) The spent fuel storage racks are designed and shall be maintained with Keff < 1 .00 iffully flooded with unborated water, which includes an allowance for uncertainties derefibed iWestifighetts Report A N4P FE; 00 11, Revisiafi I, "Mi litatie Untit 2 Specnt-He4-P riiealti+Analysis with Soluble Boroan Crodit."

d) The spent fuel storage racks are designed and shall be maintained with Keff•< .95 Vfully flooded with water borated to 600 ppm, which includes an allowance for uncertainties 49d...r.ib.d in Westinghouse ReportA . .P FE 00.11, Revision 1, "Miltane Unit 2 pent Fuel PoolGr.itiali' Ana lys, with Soluble Boron .-. dit." Replace with Ier l T.7

c1 Rogion A of the spent fi..l storage p. l is d.ign.d and shall bHi mintainded withanomfinal -9-9 in-Ph cc-ntcr. tEo cntcr. distanc bet",co traooatiorn. Fuel -assefblies star-ed inthis region mist cmpl4.with Figur- ;.9 4ito ... r nu..that the design burnup has been sustained.

f) Region B4 of the spent fuel storage -peal is designed and shall be maintatincd with -ananminal 9.8 inch eenter- to eenter- distancc betvwccf ster-age leeatiens. Reogin B eentains bothbleeked and en blocked star-age laeations, shown in Figurc 3'.9 -2. Feel ha i g a maimumfnotminal cnrifihment of 1.85 weight perccnt W 235, mfay be stored in un blocked locmatons. Fuelstar-ed in blockced ieeatians ffust be Batch B fucl asseffblies.

g) Region C= of the spent fuel stafage pool is designed an;;d sha~llb anandwt 9.0ineh ccntcr- to ccntcr- distanec bctwcct star-age laeations. Fuel assefmblies s~rdintimust comfply with Figer-s 3;.9 6a or 3.9 lb to efnsurc that the design burno up 3has bccn.R sustained.Additionally, fuoel asscmfblies uttilizing Figur-e ;.9 lb rcgquir-e that borated ~tafinles steel Pobopin arc:-ntal..d in the fuel assembly's c:nter guid. tube and in two d .iagonall, .p..it. g•uid

tuc.Thc poo pi ' arc selid 0.87 inceh 0.9. bor-atcd stainless steel, with a boroen eonttont of 2weight pcrccnt-4 boronR.

h) Region C of thc spent fade steragct pool is designed to pcrmfit ftoage of eeftsolidated

fucel. The eententq of the eefisalideAtd fuol steragc baoxc to be saor-d in thbg region rmust comfplywith F-tifur 3.9 3ý to enstir- that the design burnuitp has been sustained.

MILLSTONE - UNIT 2 Amendment No. 30, -8, -4-09,4--7,1446,44-, 172, 482, 24-4, 270, 2-74,


e) Region 1 of the spent fuel storage pool is designed and shall be maintainedwith a nominal 9.8 inch center to center distance between storage locations. Region 1contains the Restricted Locations, shown in Figure 3.9-2. Fuel having an initial nominalplanar average enrichment of 4.85 weight percent U-235 may be stored in availablelocations. No burnup credit is required.

f) Region 2 of the spent fuel storage pool is designed and shall be maintainedwith a nominal 9.8 inch center to center distance between storage locations. Region 2contains the Restricted Locations as well as Type 2A and Type 2B storage locations,shown in Figure 3.9-2. Fuel assemblies stored in this region must comply with Figure3.9-lA or Figure 3.9-11B to be in the acceptable burnup domain. Fuel assembliesutilizing Figure 3.9-1A must be stored in the Region 2 Type 2A storage locations, andfuel assemblies utilizing Figure 3.9-1 B must be stored in the Region 2 Type 2B storagelocations.

g) Region 3 of the spent fuel storage pool is designed and shall be maintainedwith a nominal 9.0 inch center to center distance between storage locations. Fuelassemblies stored in this region must comply with Figure 3.9-1C or Figure 3.9-1D to bein the acceptable burnup domain. Additionally, fuel assemblies utilizing Figure 3.9-1Crequire that borated stainless steel poison rodlets are installed in the fuel assembly'scenter guide tube and in two diagonally opposite guide tubes. The poison rodlets aresolid 0.87 inch O.D. borated stainless steel, with a boron content of 2.0 weight percentboron. Finally, fuel assemblies utilizing Figure 3.9-1 D require that a control elementassembly be installed in the fuel assembly (except for the full-length, reduced-strengthcontrol element assemblies and the part-length control element assemblies).

h) Region 3 of the spent fuel storage pool is designed to permit storage ofconsolidated fuel. The contents of the consolidated fuel storage boxes to be stored inthis region must comply with Figure 3.9-3 to ensure that the design burnup has beensustained

i) Region 4 of the spent fuel storage pool is designed and shall be maintainedwith a nominal 9.0 inch center to center distance between storage locations. Region 4contains the Restricted Locations, shown in Figure 3.9-2. Fuel assemblies stored in thisregion must comply with Figure 3.9-1 E to be in the acceptable burnup domain.

DESIGN FEATURES

DRAINAGE

5.6.2 The spent fuel storage pool is designed and shall be maintained to prevent inadvertentdraining of the pool below elevation 22'6".

CAPACITY

5.6.3 The spent fuel storage poo. ,e1 " I I 1 I| I

•LLIL•ILL•

I : D :. n -1M te EB HO ffiffe E RH sterage ae ens n e an ster-affe epý_AfHHRq- R --L-Q.P AR AR

'u'~rnus~ I'~'N1TI~fl2 ir IC'MTV'fl I T'~~ fl v'r'1I ~'T I ~'It~ '~r"rncr'~ unrv'n'~Cý&rý

The spent fuel storage pool is designed and shall be maintained with a storagecapacity limited to no more than 160 storage locations in Region 1,224 storagelocations in Region 2, 822 storage locations in Region 3, and 1410 storagelocations in Region 4 for a total of 1346 storage locations.

MILLSTONE - UNIT 2 5-5a Amendment No. 30, 5-, 4-09, 4-t-7, 446,4-5-, 4-72, -7-4,


Attachment 3

Marked-up Technical Specifications Bases Pages for Information Only

DOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT

IFOR INFORMATION ONLY AApril 1, 2003,

REFUELING OPERATIONS

The lirmta ndescribed by Figures 3.9 !a, 3.9 1 b, and 3.9 3 ensure that the reactivity offuel assemblies d consolidated fuel storage boxes; introduced into the Region G spent fuelracks, are conservatively within the assumptions of the safety analysis. N 3-

A-p be byFigre .9 estie teA he -eatim-of the fuiel assemfblies,OR uee it hr st t asurptions of the

3/4.9.19 SPENT FUEL POOL - STORAGE PATTERN

The limitations of this specification ensure that the reactivity condition of the Regionstorage racks and spent fuel pool Keff will remain less than or equal to 0.95.

11,2, and4

+h nc elt tWIeeKng Wevtees in the 4ht lee Mtauo E)1 me Hegion H~ 3tbrae faeks are desig'BeEl

to pr-event iniadve~ent plaeement anid/or- storage in the bi1 kedL leations. Th e blocked loceAtionrean mpty, or- a Bateh B fuel assemfbly mfay be stor-ed in the bloeeked location, to maintftain

r-eactivity controal fcr- fuel asseffbly storage in any adaetieftson. RegionH B (nont cell bioekerleeations) is designed fcr- the stor-age of nie", as-em~bqie in-;4 the spent fuiel pool0-, and fo-r- fuelassemblies which have not sus+taifed suffleient burnuip to be stored in Region A or 1-giafi G.

This L6 is ntie applicable during thc initial installeatin of Batch B fus-el afblieS inl thecell blocker loateians of Region B. This is acceptable beeattse only Batch -B fuel assemfblies willbe moived during the in1ititl insftallation of Baftch B futel assemblies under +he Regioni-Be1bleekers. Bateh B fuiel assemblies are qualified fcar storage in any spent fuiel pool ster-age racklocation, hence a futel mblosiading event which eauses a r-eactivity eeonsequenee is not cr-edible.This &eception is valid only dur-itg the inkitia ins~allation of B3atch B fuel assemfblies ini the cellblocker 18eaFUI E POOL -A-SO

3/4.9.20 SPENT FUEL POOL - CONSOLIDATION-- "lReplace with Insert T.6

The limitations of these specifications ensure that the decay heat rates and radioactiveinventory of the candidate fuel assemblies for consolidation are conservatively within theassumptions of the safety analysis.

MILLSTONE - UNIT 2 B 3/4 9-4 Amendment No. 4--7, 4--3, 4-5-8, --72,2-74,

Insert T.6 to TS Bases 3/4.9.19

Fuel storage rack locations designated as Restricted Locations in Figure 3.9-2 shall notbe used to store fuel assemblies (Regions 1, 2, and 4). Consolidated fuel storageboxes shall only be stored in Region 3 where there are no Restricted Locations.

There are non-standard fuel configurations and components, and non-fuel containingcomponents present in the fuel storage racks. These non-standard fuel configurationsand components, and non-fuel containing components may be stored in fuel assemblylocations if they are demonstrated to be non-limiting with respect to the fuel assembliesthat have been analyzed. The same methodology used for the analysis that establishedthe Technical Specification requirements will be employed to evaluate non-standard fuelconfigurations and components, and non-fuel containing components. These non-standard fuel configurations and components, and non-fuel containing components mayalso be stored in fuel storage rack locations designated as a Restricted Locationfollowing an evaluation utilizing the same analysis methodology employed to establishthe requirements of this Technical Specification.

Insert T.8 to TS Basis 3/4.9.18.

In addition, the requirement that Region 3 fuel assemblies contain borated stainlesssteel poison rodlets or a control element assembly ensures that the reactivity of fuelassemblies is conservatively within the assumptions of the safety analysis. Note thatthe full-length, reduced-strength control element assemblies used in Cycles 1 through 6(control element assemblies with serial numbers 66 through 73, inclusive) and the part-length control element assemblies used in Cycle 1 (control element assemblies withidentifier letters A through H, inclusive) do not satisfy this requirement, and thus are notto be used in Region 3.


Attachment 7

Affidavit of Westinghouse Electric Company, LLC


(Westinghouse Electric CompanyNuclear Services1000 Westinghouse Drive

Cranberry Township, Pennsylvania 16066USA

U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643Document Control Desk Direct fax: (724) 720-075411555 Rockville Pike e-mail: [email protected], MD 20852 Proj letter: CMIL--12-9

CAW-12-3573

November 29, 2012

APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURE

Subject: "Dominion Spent Fuel Pool Criticality Analysis - Westinghouse Proprietary Information"(Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-12-3573 signed by the owner of the proprietary information,Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basison which the information may be withheld from public disclosure by the Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission'sregulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Dominion NuclearConnecticut, Inc.

Correspondence with respect to the proprietary aspects of the application for withholding or theWestinghouse affidavit should reference CAW-12-3573, and should be addressed to James A. Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 WestinghouseDrive, Cranberry Township, Pennsylvania 16066.

Very truly yours,

i/James A. Gresham, ManagerRegulatory Compliance

Enclosures

CAW-12-3573

AFFIDAVIT

COMMONWEALTH OF PENNSYLVANIA:

ss

COUNTY OF BUTLER:

Before me, the undersigned authority, personally appeared James A. Gresham, who, being by me

duly sworn according to law, deposes and says that he is 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 his knowledge, information, and belief:

1 James A. Gresham, Manager

Regulatory Compliance

Sworn to and subscribed before me

this 29th day of November 2012

Notary Public

COMMONWEALTH OF PENNSYLVANIANotarial Seal

Anne M. Stegman, Notary PublicUnity Twp., Westmoreland County

my Commission Expires Aug. 7, 2016MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES

2 CAW-12-3573

(1) I am Manager, Regulatory Compliance, in Nuclear Services, 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) 1 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) 1 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 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 constitutes

Westinghouse policy and provides 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

3 CAW-12-3573

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.

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

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.

4 CAW-12-3573

(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.

(iii) The information is being transmitted to the Commission in confidence and, under the

provisions of 10 CFR Section 2.390, it is to be received in confidence by the

Commission.

(iv) 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.

(v) The proprietary information sought to be withheld in this submittal is that which is

appropriately marked in "Dominion Spent Fuel Pool Criticality Analysis - Westinghouse

Proprietary Information" (Proprietary), for submittal to the Commission, being

transmitted by Dominion Nuclear Connecticut, Inc. 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 rack information for criticality analysis and may be used only for that

purpose.

This information is part of that which will enable Westinghouse: to:

(a) Perform spent fuel pool analysis

5 CAW-12-3573

Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of the information to its customers for the

purpose of spent fuel pool analysis.

(b) Westinghouse can sell support and defense of spent fuel pool analysis.

(c) 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 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.


Attachment 8

Affidavit of Dominion Resources Services, Inc.



10 CFR § 2.390

APPLICATION FOR WITHHOLDINGAND

AFFIDAVIT OF J. ALAN PRICE

I, J. Alan Price, Vice President - Nuclear Engineering, state that:

1. I am authorized to execute this affidavit on behalf of Dominion ResourcesServices, Inc. (DRS).

2. Dominion Nuclear Connecticut, Inc. (DNC), an affiliate company of DRS, issubmitting a License Amendment Request, "Dominion Nuclear Connecticut, Inc.Millstone Power Station Unit 2 License Amendment Request Regarding ProposedTechnical Specifications Changes for Spent Fuel Storage" dated December 17, 2012,for NRC review and approval. The License Amendment Request updates the MillstoneUnit 2 spent fuel pool storage configuration and associated constraints and will allowelimination of reactivity credit for Boraflex panels in the spent fuel pool. This LicenseAmendment Request contains unique, first time aspects of methodologies that DRS hasutilized to analyze burnup credits for the updated spent fuel pool criticality analyses.The Proprietary Version of the License Amendment Request contains proprietarycommercial information that should be held in confidence by the NRC pursuant to thepolicy reflected in 10 CFR §§ 2.390(a)(4) because:

a. This information is being held in confidence by both DRS and DNC.

b. This information is of a type that is held in confidence by DRS and DNC, andthere is a rational basis for doing so because the information contains sensitivecommercial information to DRS regarding methods used to analyze burnup creditsas it relates to spent fuel pool criticality analyses.

c. This information is being transmitted to the NRC in confidence.

d. This information is not available in public sources and could not be gatheredreadily from other publicly available information.

e. Public disclosure of this information would create substantial harm to DRS bydisclosing the unique, first time aspects of these methodologies to other parties notinvolved in the development of the criticality analyses. The methodologies weredeveloped by DRS to analyze burnup credits for updated spent fuel pool criticalityanalyses in order to meet recent NRC Interim Staff Guidance (NRC Document DSS-ISG-2010-01, Revision 0, "Staff Guidance Regarding the Nuclear Criticality SafetyAnalysis for Spent Nuclear Fuel Pools," 9/29/2011) and NUREG/CR-7108 and


NUREG/CR-7109. DRS has expended significant engineering resources in thedevelopment of this information. Therefore, disclosure of this information to otherparties would permit them to use the information without the expenditure of similarresources, thus giving them a competitive advantage.

3. Accordingly, DRS requests that the designated document be withheld from publicdisclosure pursuant to the policy reflected in 10 CFR §§ 2.390(a)(4).

DominionRe urces Services Inc.

J. Alq PrVicePreis ent - Nuclear Engineering

VICKI L. HULLSTATE OF I _ _ _ I_ A Notary Public

Commonwealth of Virginia

COUNTY OF My Commission Expires May 31, 2014

Subscribed and sworn to me, a Notary Public, in and for the County and Stateabove named, this "- day ofbec.r•-y,,er ,2012.

I ck i\ ý-QMy Commission Expires: 5-3 L (

Documents

Dominion Nuclear Connecticut, Inc. Dominion® · Dominion® 5000 Dominion Boulevard, Glen Allen, VA 23060 Web Address: Proprietary Information - Withhold Under 10 CFR 2.390 December