1CAN069104, Application for Amend to License DPR-51,replacing Existing Footnote in Tech Spec 3.8.15 to Allow Spent Fuel Cask to Be Handled by Auxiliary Bldg Crane for Period 911015-920131 for Shipment of Two Spent Fuel Rods Utilizing 17-ton Cask
| ML20077H070 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 06/27/1991 |
| From: | Carns N ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20077H071 | List: |
| References | |
| 1CAN069104, 1CAN69104, NUDOCS 9107050115 | |
| Download: ML20077H070 (9) | |
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Operations 7,o "W 4 Bade "2a Hell 6, "Duaa" Carns wee Wnoent Opmahr>ns ANO June 27.-1991 1CAN069104 U. S. Nuclear Regulatory Commission Document Control Desk Hall Station P1-137 Weshington, D. C.
20555
Subject:
Arkansas Nuclear One - Unit 1 Docket No. 50-313 License No. DPR-51 Technical Specification Change Request Auxiliary Building Crane Gentlemen:
Over the last 13 years Arkansas Nucinar One, Unit 1 (ANO-1),.in association with Babcock & Wilcox (B&W), the ANO-1 fuel vendor, has act1vely participated with the U.S. Department of Energy in nuclear fuel evtended burnup programs. ANO-1.is currently working with B&W.in continued activities relating to their extended nuclear fuel burnup program. One of these activitlen involves the shipment of two fuel rods from ANO-1 to Sweden for a joint B6W and Studsvik Nuclear hot cell examination of high burnup fuel.
Thin is scheduled to occur between October 15, 1991 and January 31, 1992.
The current ANO 1 Technical Specification (TS) 3.8.15 prohibits the handling of a spent fuel snipping cask with the Aux 1.11ary Building crane.
This constraint was made by ANO-1 TS Amendment 17, dated December 17, 1976 (1CNA127641), pending NRC evaluation of the spent fuel cask drop accident and the crane design by Arkansas Power & Light (AP&L) and NRC review and approral.
ANO-1 TS Amendment 36, dated October 5, 1978 (ICNA107805), allowed the crano to be utilized during Cycle 3 to handle a cask for removal and l
shipment of some irradiated burnable poison rod test assemblies.
Subsequent to the issuance of Amendment 36, AP&L confirmed its earlier request for the unlimited use of the Auxiliary Building crane to allow additional shipments utilizing the NAC-1 cask vin letter ICAN018018, to the attention of Mr. W1111a s 9, Miller dated January 21, 1980.
The docket ooes not indicate complotion of this review.
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On July 10,-1987, ANO-1 TS Amendment 107 was-issued to allow another "on, time exception" to the TS to handla a spent fuel shipping cask containing six spent fuel rods.
The request for that TS change trnusmitted by our letter dated April 7, 1987 (ICAN048701), originally requested deletion of TS 3.8.15, but the request was modified by our letter dated May 6,1987 g
(ICAN058701), for the one time exception.
The change was necessary to f\\
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ali w the NRC staff additional time to complete the review for delet fon of o
the TS and to accommodate the time restriction due to limited availability of a DOE spent fuel shipping cask.
Subsequently, in NRC's letter of December 16, 1987 (ICNA128703), ANO was informed that the NRC was terminating further review of our original request to delete TS 3.8.15.
ANO plans to resubmit a Th Change Request to delete TS 3.8.15.
Ilowev e r,
this will require several months to research previous analyses and to prepare the submittal. Therefore, the purpose of this request. is to gain another exception to TS 3.8.15 in order to accominodat e the shipment of the two spent fuel rods as early as October 15, 1991.
The circumstances of this proposed TS amendment request are not of an exigent. or emergency nature; however, expedit.lous handling is requested of the exception request due to limited availability of a suitable shipping
- cask, in accordance with 10CFR50.91(a)(1), Entergy Operations has evaluated the proposed change using the criteria in 10CFR50.92(c) and has determined that this change involves no significant hazards considerations.
We request that the effective date of this amendment be upon issuance in order to take immediate advantage of the change.
Sincerely, 6d
- g. N J C-NSC/kdw Attachments cc:
Mr. Robert Martin U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 NRC Resident inspector Arkansas Nuclear One - ANO-1 & 2 Number 1, Nuclear Plant Road Russellville, AR 72801 Thomas W. Alexion NRR Project Manager, Region IV/ANO-1 U. S. Nuclear Regulatory Commission NRR Mail Stop ll-D-23 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852 1
U. S. NRC-June _27, 1991
,Page 3 cci Ms. Ghnri Peterson NRR Project. Manager, Region IV/ANO-2 U. S. Nuclear Regulatory Commission j
NRR Mail Stop 11-D-23 One White Flint North 11555 Rockv111e Pike Rockville, Maryland 20852 Hs. Greta Dieus, Director Arkansas Department of llenith Division of Radiation Control j
and-Emergency Management 4815 W. Markham Street i
Little Rock,'AR 72205 4
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4 STATE OF ARKANSAS
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W. Yelverton, being duly sworn, subscribe to and say that I am General Manager, Plant Operations for Arkansas Nuclear One; _ t hat I IInve full authority to execut.c this oath; that I have read the document numbered 1CAN069104, and know the contents thereof; and that to the best of my knowledge, information and belief the statements in it nru true.
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J. W. plverton-SUBSCRIBED AND SWORN'To before me, a Notary Public in and for the County and State ' above nr.med, this M//[ day of S&C. -
- 1991.
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ENCLOSURE PROPOSED TECilNICAL SPECIFICATION AND RESPECTIVE SAFETY ANALYSES _
TN Tile MATTER OF AMENDING LICENSE NO. DPR-51 ENTERGY OPERATIONS, INC.
ARKANSAS NUCLEAR ONE, UNIT 1 DOCKET No. 50-313 l-i-
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. l' rop 0SEIMMNGE The proposed change will replace the exist ing footnot e to the Arkansas Nuclear One, Unit 1 (ANO-1) Technical Specification (TS) 3.8.15 wit h one which will allow a spent fuel cask to be handled by the Auxiliary Building crane for the period of October 15, 1991, through January 31, 1992, for the shipment of two spent fuel rods utflizing a 17 ton shipping cask.
BACKGROUND The proposed amendn.ent request would revise the ANO-1 TS to allow an except. ion to TS 3.81 15 to allow the Auxiliary Building crane to handle a spent fuel shipping cask for the purpose of shipping two spent fuel rods.
This change request is similar to Amendment 107, dated July 10, 1987, and is proposed to allow use of the cask to meet a schedule constraint. pending the snbmittal and review of a TS change to delete TS 3.8.15.
TS 3.8.15 present'y states that a spent fuel shipping cask shall not be carried by the Auxiliary Building crano pending the evaluation of the spent fuel cask drop accident and the crano design by Arkansas Power & bight (Ap&L) and NRC review and approval. The related Bases states that upon satisfactory completion of the NRC's review, TS 3.8.15 shall be deleted.
TS 3.8.15 assures that the spent fuel cask drop accident cannot occur prior to completion of the NRC staf f's review of this potent ial accident and the completion of any modifications that may he necessary to preclude the accident or mitigate the consequences.
NRC review of this particular issue was incorporated into the staf f's resolution of the Generic Issue A-36 related to control of heavy loads near spent fuel.
AP&L has completad all actions and submittals required by the issuance of NUREG-0612 " Control of Heavy Loads at. Nuclear Power plants," as evidenced by NRC Saf ety Evaluation Report (SER) dated October 11, 1984, and Generic I,etter 85-11 dated June 28, 1985. Generic Letter 85-11 indicated that application for a license amendment may be submitted to delete related 1teense conditions citing Generic Letter 85-11 as the basis.
DISCUSSION In mid 1978, AP&L and B&W began a joint program supported by DCE to design, Irradiate, and examine an improved PWR fuel assembly (the Mark BEB) cnpable of operating to burnups in excess of 50,000 MWD /MTU.
Four Mark BEB assemblies were manuf actured which incorporated features such as annealed guide t ubes, thicker clad, increased plenum volume, lower fill pressure and Inconel 718 hold down springs in place of inconel X-750 springs.
In addition, a few roda with annular pellets and some segmented rods with both solid and annular pellets were included.
The assemblies were exposed in ANO-1 for Cycles 5, 6 and 7 during the period f rom March 1981, to September 1986, and achieved an average burnup of 47,000 MWD /M'lU.
In July 1987, six peripheral rods were extracted from assembly NJ023Q and sent to the B&W hot cell for examination. Further details and a summary of the hot colI results are presented in DOE report, DOE /ET/34213.16 (BAW-1523.13)
. dated December 1990. Although not part of the DOE program, one of the assemblics (NJ023P) was irradiated a fourth timn to achievo a burnup of 57,152 MWD /HTU by the nnd of Cycle. 8 in August 1988.
New thn B&W Fuel Company wishes to send two segmented funi rods from this assembly to Studsvik Nuclear.-Nykoping, Sweden for ramp testing and further examinations.. Transportation of the rods will be by Edlow Internat.ional using a 17 ton cask. The shipment of six rods that occurrnd in JAugust 1987, used a 25 ton cask that.'was handled by the Auxiliary Building crano under the provisions of Amendment 107 to the ANO-1 licenso.
The same precautions taken to accommodate the 25 ton cask movement will be used for this shipment. The precautions, which worn outlined in the NRC Safnty Evaluation for Amendment 107 are as follows:
1.
An automatic limit switch and a power disconnect from the main contact rails'will be provided on thn Auxiliary Building crano to precludo cask travel over the spent fuel storage pool.
2.
Interlocks will also be used to limit the height to which thn cask is raised above the floor.
3.
Further hoist operat.f on will be prevented by an electrical interlock and-the crano hoist con + rol circuit.s will bn disabled under administrative controls once the cask has been raised to the proper height. Consequently, changes in ensk height will be prevented during horizontal movement.-
4.
Cask travel-within safo-load areas is limited by strict administrat.1ve controls-in combination with interlocks which limit crane travol to within. normal-crane load handling areas.
DETERMINATION OF SIGNIFICANT HAZARDS An : evaluation of. the proposed chango has boca performed in accordanco with -
10CFR50.91(a)(1), regarding no significant hazards consideration using the standards in 10CFR50.92(c). A discussion of those standards as they relate to this amendment request follows:
driterion 1 - Involyn a Significant. Increase in thn' probability or Consequences of an Accident Previously Evaluated.
-AN0's p*oceduros, load pat,hs, crano equipment certification, operator
- training and other related heavy load handling topics wero evaluated as part.' of the control of 'honvy londs issue and found acceptable. - Spent' fuel cask handling is discussed in Sect.lon 9.6.2.6 of-the ANO-1 SAR, which shows that the cask will nov'er travel.over spent fuel. -Although cask handling is presently prohibited by TS 3.8.15, ANO-1 SAR Section 9.6.2.6 further evaluates.the-unlikely event of a c4sk drop accident and shows that the consequences are acceptable. 'An exception to TS 3.8.15 to allow handling.
of a spent fuel shipping cask by tho-Aux 111ary Building crano will have no actunt impact on the cask drop or any other previously analyzed accident.
The cask drop ovaluation in ANO-1 SAR Section 9.6.2.6 assumes 15 full fuel assemblies, 100 days af ter shutdown, are involved.
Although the Dor; extended burnup fuel assemblies havn longer operation than the three cycles assumed in the SAR evaluation, they have been stored in the ANO-1 fuel pool much longer than the assumed 100 days, thus the lodine and nobic gas inventory available for release has decreased substantially due to isotopic decay. The proposed amendment will allow the movement of only 2 spent fuel rods, a very small fraction of the number of rods in 15 full assemblics (3120 fuel rods). The SAR analysis assumes twenty-five percent of the noble gases and ten percent of the available iodine from all 3120 fuel rods is released.
This would be equivalent to the complete release of noble gases and iodine from several hundred individual rods.
Therefore, the ofisite doses resulting from a cask drop would be much lower than those presented in the SAR. Additionally, this is a one time exception request; only one cask will be moved which represents only a small increase in the probability of a cask drop accident due to reliability of the equipment and precautions utilized. This amendment request, therefore, does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Criterion 2 - Create the Possibility of a New or Different Kind of Accident From any Accident Previously Evaluated.
The proposed amendment request will allow handling of a spent fuel shipping cask by the Auxiliary Building crane where previously prohibited due to pending NRC evaluation of the spent fuel cask drop accident and the crane design by AP&L and NRG review and approval.
The cask handling methods and cask drop accident are discussed and evaluated in ANO-1 SAR Section 9.6.2.6.
Additionally, the NRC performed an independent evaluation of the radiological consequences of a cask drop sccident, as documented in the ANO-1 SER dated June 6, 1973. The evaluation of the unlikely event of a cask drop eccident included assessment of equipment failures and has shown the consequences to be within acceptable bounds. No new accident scenarios can be identified related to the proposed amendment request, therefore, this change is bounded by the current analysis in the SAR. The proposed amendment request will, therefore, not create the possibility of a new or dif ferent kind of accident from any accident previously evaluated.
Criterion 3 -
Involve a Significant Reduction in the Margin of Safety.
Although allowing une of the Auxiliary Building crane where previously prohibited by the TS could increase the possibility of a cask drop accident, the margin of safety is preserved in that the acceptable consequences of the cask drop accident evaluation in SAR Section 9.6.2.6 are not affected by this change.
The proposed amendment request will not adversely affect the adequacy and conservatism of the cask drop accident evaluation. The spent fuel cask certificate has boon issued and continues to hold an NRC Certificate of Compliance for radioactive materials packages, and load paths and equipment to be used for cask handling have been reviewed and approved by the NRC with the resolution of the control of heavy loads issue. Additionally, this proposed amendment allows a one time use of the cask, which represents only a small increase in the probability of a cask drop accident due to the reliability of the equipment an '
precautions utilized. Therefore, the cask handling issue at ANO-1 continues to exhibit an acceptable margin of safety and this amendment request will not invo tvo a significant reduction in the margin of safety.
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' The Commission bas also provided guidanen concerning the application of
.these standards'by providing examples.
This TS change request most closely matches example (iv):
"A rollof granted upon demonstration of accept ablo operation f rom an operating restriction that-was imposed because acceptable operation was not yet. demonstrated."
In this cass, demonstration of acceptable operat ion. nppltos to the acceptable resolution of.the NRC review of the control of hoavy loads issun for ANO-1, as-woll as the original FSAR analysis of the of fs tto doso consequences of. a cask drop accident which were accepted by the NRC with issuanco ~ of the ANO-1 SER.
It. should also be noted that exceptions to i
TS 3.8.15 have been allowed by the NRC to allow cask handling for burnable i
poison rod assemblies during Cycle 3 operat ion (TS Amendment 36, dated October 5, 1978) and six spent funi rods in 1987 (TS Amendment 107, dated July 110, 1987).
- Based on the abovn discussion and ovaluation, Ent ergy 0porat.f ons concluded
.a that the proposed TS amendment request monts the standards.for determining
= that no.significant hazards consideration is involved and, therefore, concluded that this amendment application. involves no significant. hazards considerations.
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