L-06-094, License Amendments Request Nos. 333 and 204

License Amendments Request Nos. 333 and 204

ML061700101
Person / Time
Site:	Beaver Valley
Issue date:	06/14/2006
From:	Lash J FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-06-094
Download: ML061700101 (31)

Text

FENOC FirstEnergy Nuclear Operating Company James H. Lash 724-682-5234 Site Vice President Fax: 724-643-8069 June 14, 2006 L-06-094 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Beaver Valley Power Station, Unit Nos. 1 and 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 License Amendments Request Nos. 333 and 204 Pursuant to 10 CFR 50.90, FirstEnergy Nuclear Operating Company (FENOC) requests amendments to the above licenses in the form of changes to the Beaver Valley Power Station (BVPS) Technical Specifications. The License Amendment Requests (LAR) propose Technical Specification changes that will incorporate the results of a new spent fuel pool criticality analysis documented in WCAP-1 6518-P/ WCAP-l 6518-NP, "Beaver Valley Unit 2 Spent Fuel Pool Criticality Analysis," Revision 1, May 2006 (Reference 1) for the BVPS Unit No. 2 spent fuel storage pool. The new criticality analysis will permit utilization of vacant storage locations dictated by the existing Technical Specification storage configurations in the Unit No. 2 spent fuel storage pool. contains the FENOC evaluation of the proposed changes. This enclosure contains markups of the Technical Specification and Technical Specification Bases pages with the proposed changes. contains WCAP-1 6518-P Revision 1, "Beaver Valley Unit 2 Spent Fuel Pool Criticality Analysis," May 2006 (Proprietary version). contains WCAP-16518-NP Revision 1, "Beaver Valley Unit 2 Spent Fuel Pool Criticality Analysis," May 2006 (Non-proprietary version). contains a Westinghouse authorization letter, CAW-06-2142, accompanying affidavit, Proprietary Information Notice, and Copyright Notice. As WCAP-16518-P Revision 1 contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, the owner of the information.

The affidavit sets forth the basis on which the requested information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.

(c

Beaver Valley Power Station, Unit Nos. 1 and 2 License Amendment Request Nos. 333 and 204 L-06-094 Page 2 Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to the copyright or the proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CAW-06-2142 and should be addressed to B. F. Maurer, Acting Manager Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P. 0. Box 355, Pittsburgh, PA 15230-0355.

These changes have been reviewed by the BVPS review committees. The changes were determined to be safe and do not involve a significant hazard consideration as defined in 10 CFR 50.92 based on the attached safety analysis and no significant hazard evaluation.

FENOC requests approval of the proposed amendments by June 2007 to support the Unit No. 2 refueling outage scheduled for the spring of 2008. Once approved, the amendment shall be implemented within 30 days. FENOC also requests that by October 31, 2006, the NRC communicates to FENOC any known significant concerns that would negatively impact the likelihood of amendment approval. This request is being made to provide ample time for FENOC to pursue an alternate approach to recover the empty storage cells in the Unit No. 2 spent fuel storage pool should these license amendment requests not be approved.

No new regulatory commitments are contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Gregory A. Dunn, Manager, FENOC Fleet Licensing, at (330) 315-7243.

I declare under penalty of perjury that the foregoing is true and correct. Executed on June 114 2006.

Sincerely,

,7msH.

Lash

Reference:

1.

WCAP-16518-P/ WCAP-16518-NP, "Beaver Valley Unit 2 Spent Fuel Pool Criticality Analysis," Revision 1, May 2006.

Beaver Valley Power Station, Unit Nos. 1 and 2 License Amendment Request Nos. 333 and 204 L-06-094 Page 3

Enclosures:

1 FENOC Evaluation of the Proposed Changes 2

WCAP-16518-P Revision 1, "Beaver Valley Unit 2 Spent Fuel Pool Criticality Analysis," May 2006 (Proprietary version).

3 WCAP-16518-NP Revision 1, "Beaver Valley Unit 2 Spent Fuel Pool Criticality Analysis," May 2006 (Non-proprietary version).

4 Westinghouse authorization letter, CAW-06-2142, accompanying affidavit, Proprietary Information Notice, and Copyright Notice c:

Mr. T. G. Colbum, NRR Senior Project Manager Mr. P. C. Cataldo, NRC Senior Resident Inspector Mr. S. J. Collins, NRC Region I Administrator Mr. D. A. Allard, Director BRP/DEP Mr. L. E. Ryan (BRP/DEP)

ENCLOSURE 1 FENOC Evaluation of the Proposed Changes Beaver Valley Power Station License Amendment Request Nos. 333 and 204

Subject:

New Spent Fuel Storage Configuration Table of Contents Section Title Page 1.0 D ESCRIPTION..........................................................................

1

2.0 PROPOSED CHANGE

S............................................................

1

3.0 BACKGROUND

3

4.0 TECHNICAL ANALYSIS

5 5.0 REGULATORY SAFETY ANALYSIS...............................

7 5.1 No Significant Hazards Consideration...................................

8 5.2 Applicable Regulatory Requirements/Criteria....................

10

6.0 ENVIRONMENTAL CONSIDERATION

12

7.0 REFERENCES

12 Attachments A

Proposed Technical Specification Changes B

Proposed Technical Specification Bases Changes Page i

Beaver Valley Power Station License Amendment Request Nos. 333 and 204

1.0 DESCRIPTION

This is a request to amend Operating Licenses DPR-66 (Beaver Valley Power Station Unit No. 1) and NPF-73 (Beaver Valley Power Station Unit No. 2). The proposed changes to the Beaver Valley Power Station (BVPS) Operating Licenses will revise the Technical Specifications to incorporate the results of a new spent fuel pool criticality analysis for Unit No. 2. The new criticality analysis will permit utilization of vacant storage locations dictated by the existing Technical Specification storage configurations in the Unit No. 2 spent fuel pool.

2.0 PROPOSED CHANGE

S On February 25, 2005, FirstEnergy Nuclear Operating Company (FENOC) submitted License Amendment Request (LAR) Nos. 296 (Unit No. 1) and 169 (Unit No. 2) to convert the current Beaver Valley Power Station (BVPS) Technical Specifications to the Improved Standard Technical Specifications, NUREG-1431, "Standard Technical Specification - Westinghouse Plants." The February 25, 2005 submittal requested an approval date of August 2006 and an amendment implementation date of at least 150 days. The current plan is to implement the converted BVPS Technical Specifications before the end of 2006. Since implementation of the converted BVPS Technical Specifications is expected prior to approval of this LAR, proposed changes to the BVPS Technical Specifications are submitted for NRC review and approval in the Improved Technical Specification (ITS) format. These changes are provided in Attachment A'. The changes proposed to the Technical Specification Bases in the ITS format are provided in Attachment B'. The following discussion of the proposed changes refer to the ITS format of the BVPS Technical Specifications and Bases.

To meet format requirements the Index, Technical Specifications and Technical Specification Bases pages will be revised and repaginated as necessary to reflect the changes being proposed by this LAR.

Technical Specification 3.7.14 Change Technical Specification 3.7.14, Spent Fuel Pool Storage, is modified by specifying a series of spent fuel storage configuration tables for Unit No. 2. References to the tables are added to the Limiting Conditions for Operation (LCO), Required Action A.1 and Surveillance Requirement 3.7.14.1. The Unit No. 2 fuel storage The proposed changes to the Technical Specifications and Technical Specification Bases have been prepared electronically. Deletions are shown with a strike-through and insertions are shown double-underlined. This presentation allows the reviewer to readily identify the information that has been deleted and added.

Page 1

e Beaver Valley Power Station License Amendment Request Nos. 333 and 204 configuration specific tables are added to the Technical Specification as Tables 3.7.14-2 through 3.7.14-6. Accordingly, the Unit No. 1 table has also been renumbered. References to the Unit No. 1 table throughout Technical Specification 3.7.14 have also been changed to reflect the new table number. The LCO and the Surveillance Requirement have been revised to remove references to initial enrichment and burnup.

The justification for the change to Technical Specification 3.7.14 is a new criticality analysis documented in WCAP-16518-P/ WCAP-16518-NP, "Beaver Valley Unit 2 Spent Fuel Pool Criticality Analysis," Revision 1, May 2006 (Reference 1).

The proposed rewording of the LCO and Surveillance Requirement retains the requirement to meet the applicable fuel storage parameters without repeating the parameters in the LCO and Surveillance Requirement. Burnup and enrichment are specified in the Unit No. 1 table. However the Unit No. 2 tables specify burnup, enrichment, decay, interface requirements and number of Integral Fuel Burnable Absorber (IFBA) pins. The change to the Unit No. 1 table number and the change to the LCO and Surveillance Requirement have no effect on the new Unit No. 2 criticality analysis and the resultant Unit No. 2 spent fuel storage configuration.

These changes are considered editorial and, thus, do not require any further technical discussion.

Technical Specification Bases Change Technical Specification Bases 3.7.14 is revised to reflect the changes to the Technical Specification, the new criticality analysis and the renumbering of the tables.

The justification for the change to Technical Specification Bases 3.7.14 is the new criticality analysis documented in Reference 1.

The proposed Technical Specification Bases do not require NRC approval. The Beaver Valley Power Station Technical Specification Bases Control Program controls the review, approval and implementation of Technical Specification Bases changes. The change to Technical Specification Base 3.7.14 is provided for information only.

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Beaver Valley Power Station License Amendment Request Nos. 333 and 204

3.0 BACKGROUND

Existing Licensing Basis FENOC previously submitted a Unit No. 2 license amendment request to credit boron in the spent fuel pool. This request was granted in Amendment 128 on February 11, 2002 (Reference 4).

The credit for soluble boron in the spent fuel rack criticality analysis was based on the methodology described in Westinghouse topical report WCAP-14416-NP-A, Revision 1, "Westinghouse Spent Fuel Rack Criticality Analysis Methodology,"

(Reference 2). This report was approved by the NRC on October 25, 1996 and issued by Westinghouse in November 1996.

The methodology of WCAP-14416-NP-A provided for limited credit for soluble boron in the spent fuel pool to maintain kerr < 0.95. The criteria set forth in this topical report were that keff remains less than unity with zero soluble boron and that keff remains less than or equal to 0.95 with credit for soluble boron with a 95%

probability at a 95% confidence level (95/95). Fuel enrichments up to 5 weight percent (5 w/o) U-235 were considered in the analysis. In some cases, it was necessary to credit bumup in order to ensure that the spent fuel pool ker remained less than unity with zero soluble boron.

Issues With Current Licensing Basis Methodology Subsequent to the issuance of WCAP-14416-NP-A, Westinghouse issued a Nuclear Safety Advisory Letter (NSAL-00-015) reporting potential non-conservatisms in the axial shape bias and the reactivity equivalencing techniques used in the analysis. In addition, Regulatory Issue Summary (RIS)01-012, "Nonconservatism in Pressurized Water Reactor Spent Fuel Storage Pool Reactivity Equivalencing Calculations," (Reference 3), was issued to notify the industry of these issues.

An evaluation of these non-conservatisms was performed for BVPS Unit No. 2 as part of NSAL-00-015. This evaluation resulted in the use of margin in the existing analysis to demonstrate that the current Technical Specifications continue to provide their intended level of protection.

Page 3

I Beaver Valley Power Station License Amendment Request Nos. 333 and 204 Proposed Changes to Licensing Basis Westinghouse performed a new criticality analysis using methods that address the non-conservatisms of WCAP-14416-NP-A, Revision 1 (Reference 2). The new analysis is documented in WCAP-16518-P/ WCAP-16518-NP, "Beaver Valley Unit 2 Spent Fuel Pool Criticality Analysis", Revision 1, May 2006 (Reference 1).

The methodology is analogous to that described in WCAP-14416-NP-A; however the 2D-to-3D axial bumup biasing methodology is not used. Instead, the 3D axial bumup distribution effects are explicitly modeled. Reactivity equivalency techniques were not used in the new analysis.

The new criticality analysis for BVPS Unit No. 2 spent fuel rack utilizes methods that address the non-conservatisms previously described to provide more flexibility in the utilization of existing space in the spent fuel pool. The results of the analysis provided updated soluble boron, burnup credit, decay credits, IFBA credit requirements and specific storage configurations. No physical plant changes are being made (no changes to the spent fuel pools or racks, heat loads, supporting systems, etc.).

Precedent The application of the methods used in the new criticality analysis has been approved by the NRC for the following plants.

" R. E. Ginna (Amendment 79 to Facility Operating License DPR-18, dated December 7, 2000),

" Diablo Canyon Power Plant (Amendment 154 to Facility Operating Licenses DPR-80 and DPR-82, dated September 25, 2002),

" Millstone Power Station Unit 2 (Amendment 274 to Facility Operating License DPR-65, dated April 1, 2003) and

" Vogtle Electric Generating Plant (Amendment 139 to Facility Operating License NPF-68 and Amendment 118 to Facility Operating License NPF-81, dated September 22, 2005).

The methodology has been reviewed and determined to be applicable to BVPS Unit No. 2.

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Beaver Valley Power Station License Amendment Request Nos. 333 and 204

4.0 TECHNICAL ANALYSIS

The new criticality analysis, documented in Reference 1, provides the enrichment, decay, bumup, and IFBA limits, and identifies specific storage configurations required to comply with 10 CFR 50.68, "Criticality accident requirements." The boron dilution evaluation that supported Amendment 128 (Reference 4) to permit credit for soluble boron at BVPS Unit No. 2 continues to remain valid. Consistent with the analysis supporting Amendment 128, the new criticality analysis does not take credit for the Boraflex, a neutron absorber material, currently in the Unit No. 2 spent fuel pool.

The primary objectives of the new criticality analysis documented in Reference 1 are as follows:

1. To determine the fuel assembly bumup versus initial enrichment limits required for safe storage of fuel assemblies in the "All Cell," "1-out-of-4 5.0 w/o at 15,000 MWD/MTU" and "l-out-of-4 3.85 w/o Fresh with IFBA" storage configurations.

2. To determine the burnup versus initial enrichment limits required for safe storage of fuel assemblies in the "3x3" configuration with credit for 5, 10, 15, and 20 years of Pu-241 decay.

3. To determine the number of IFBA pins versus initial enrichment limits required for safe storage of fuel assemblies in the "l-out-of-4 3.85 w/o Fresh with IFBA" storage configuration.

4. To determine that fuel rod storage canisters containing fuel rods with a maximum enrichment of 5.0 w/o U-235 may be safely stored in any storage configuration.

5. To determine the assembly loading requirements at the interface between storage configurations.

6. To determine the amount of soluble boron required to maintain keff less than or equal to 0.95 in the spent fuel pool, including all biases and uncertainties, assuming the most limiting plausible reactivity accident.

These objectives were met and resulted in the Technical Specification changes being proposed by this LAR.

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Beaver Valley Power Station License Amendment Request Nos. 333 and 204 Calculations were performed for the entire pool with various fuel storage configurations to demonstrate that the keff for the entire pool remains below 1.0 with zero soluble boron. Computer modeling was used to determine the soluble boron requirements for non-accident and accident conditions to ensure that kefr remains less than or equal to 0.95.

The new criticality analysis demonstrates that kerr remains below unity for the various storage configurations considered with zero soluble boron and that krr remains less than or equal to 0.95 for the entire pool with credit for soluble boron under non-accident and accident conditions with a 95% probability at a 95%

confidence level (95/95).

The new criticality analysis also determined that the most limiting plausible reactivity accident is the misloaded fresh fuel assembly (5.0 w/o U-235 enrichment) in an incorrect storage rack location for the "l-out-of-4 5.0 w/o at 15,000 MWD/MTU" configuration.

Boron Dilution Event A spent fuel pool dilution evaluation was presented in support of Amendment 128 (Reference 4). The dilution evaluation addressed a dilution from the minimum boron concentration requirement of 2000 ppm to 450 ppm. The evaluation concluded, and the staff agreed, that an unplanned or inadvertent event that would dilute the spent fuel pool to 450 ppm is not credible for BVPS Unit No. 2. The new analysis calculates that 441.8 ppm of soluble boron is needed to maintain keff less than or equal to 0.95, including all biases and uncertainties. Thus, no new dilution evaluation is required for the changes proposed by this LAR.

Conclusions Based on the results of the analysis discussed above and in Reference 1, the following conclusions can be drawn:

1. kff remains below unity for the various storage configurations considered with zero soluble boron with a 95% probability at a 95% confidence level (95/95) thereby meeting the requirements of Title 10 of the Code of Federal Regulations, Part 50 (10 CFR 50), Appendix A, General Design Criteria (GDC) 62.

2. kerr remains less than or equal to 0.95 for the entire pool with credit for soluble boron under non-accident and accident conditions with a 95%

probability at a 95% confidence level (95/95).

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Beaver Valley Power Station License Amendment Request Nos. 333 and 204

3. The current minimum spent fuel pool boron concentration limit in Technical Specification 3.7.16 and the current dilution eVent analysis continue to ensure that any credible dilution event could be terminated before reaching a boron concentration corresponding to kerr greater than 0.95.

5.0 REGULATORY SAFETY ANALYSIS The current licensing basis for Beaver Valley Power Station (BVPS) Unit No. 2 permits credit for soluble boron in the spent fuel rack criticality analysis. This analysis is based on the methodology described in Westinghouse topical report WCAP-14416-NP-A, Revision 1, "Westinghouse Spent Fuel Rack Criticality Analysis Methodology." Regulatory Issue Summary (RIS)01-012, "Nonconservatism in Pressurized Water Reactor Spent Fuel Storage Pool Reactivity Equivalencing Calculations," dated May 18, 2001, notified the industry of potential non-conservatisms in the axial shape bias and the reactivity equivalencing techniques used in this analysis. An evaluation of these non-conservatisms was performed for BVPS Unit No. 2 that resulted in the use of margin in the existing analysis to demonstrate that the current Technical Specifications continue to provide their intended level of protection.

FirstEnergy Nuclear Operating Company (FENOC) has chosen to perform a new criticality analysis for the BVPS Unit No. 2 spent fuel storage racks that will permit utilization of vacant storage locations dictated by the existing Technical Specification storage configurations in the Unit No. 2 spent fuel pool. The new criticality analysis also uses methods that address the non-conservatisms identified in RIS 01-012. The analysis is documented in WCAP-16518-P/ WCAP-16518-*

NP, "Beaver Valley Unit 2 Spent Fuel Pool Criticality Analysis," Revision 1, May 2006. The methodology is analogous to that described in WCAP-14416-NP-A, however the 2D-to-3D axial bumup biasing methodology is not used. Instead, the 3D axial bumup distribution effects are explicitly modeled. Reactivity equivalency techniques were not used in the new criticality analysis.

This License Amendment Request (LAR) proposes revisions to BVPS Improved Technical Specification 3.7.14, Spent Fuel Storage, which is common to both BVPS units. As a result, some editorial changes are made to retain the dual unit commonality of the Technical Specification. The editorial changes consist of renumbering the Technical Specification tables and removing details of storage requirement parameters from the Limiting Conditions for Operation (LCO) and the Surveillance Requirement. The proposed rewording of the LCO and Surveillance Requirement retains the requirement to meet the applicable fuel storage parameters Page 7

Beaver Valley Power Station License Amendment Request Nos. 333 and 204 without repeating the parameters in the LCO and Surveillance Requirement. The editorial changes do not impact the changes being made to reflect the results of the new Unit No. 2 criticality analysis. The methodologies used for the new criticality analysis have been previously approved for use by the NRC.

5.1 No Significant Hazards Consideration FirstEnergy Nuclear Operating Company (FENOC) has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No. The relevant accidents previously evaluated are limited to the fuel handling and criticality accidents.

Administrative controls during fuel fabrication ensure that the fuel is fabricated to ensure proper loading of fuel in the fuel assemblies.

Administrative and operational controls used to load fuel assemblies into the spent fuel pool ensure that fuel assemblies are stored in compliance with the allowed storage configurations. Fuel handling is performed under administrative controls and physical limitations.

These controls will remain in effect and continue to protect against criticality and fuel handling accidents involving new storage configurations dictated by the new analysis. There is therefore no impact on the probability of fuel handling or criticality accidents.

The new criticality analysis defines new spent fuel storage configurations with new enrichment and bumup limits. Integral Fuel Burnable Absorber (IFBA) limits are used to comply with the 1-out-of-4 configuration for fresh fuel. The boron dilution evaluation that supported Amendment 128, permitting credit for soluble boron at BVPS Unit No. 2 continues to remain valid. The new analysis demonstrates that kerr remains below unity for the various storage configurations considered with zero soluble boron, and that kerf remains less than or equal to 0.95 for the entire pool with credit for soluble boron under non-accident and accident conditions with a 95%

probability at a 95% confidence level (95/95). Potential consequences of accidents previously analyzed remain unchanged.

Page 8

iib Beaver Valley Power Station License Amendment Request Nos. 333 and 204 The editorial changes made to the table numbers and the LCO and Surveillance Requirement wording do not impact probability or consequences of an accident previously evaluated.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

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

Response: No. The relevant types of accidents previously evaluated are limited to criticality and fuel handling accidents. Although the new analysis will allow utilization of additional storage capacity, implementation of fuel loading configurations and fuel handling activities will continue to be performed under administrative and operational controls. No new or different activities are introduced as a result of the proposed changes. The utilization of additional storage capacity within the allowances of the revised analysis will introduce no new or other kind of accident.

The editorial changes made to the table numbers and the LCO and Surveillance Requirement wording do not impact any previously evaluated accident.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3.

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

Response: No. The margin to safety with respect to analyzed accidents involves maintaining keff through fuel storage configurations and boron concentration controls in the spent fuel pool. The boron dilution evaluation that supported Amendment 128 permitting credit for soluble boron at BVPS Unit No. 2 remains valid. The Amendment 128 evaluation concluded that a boron dilution event is not credible for BVPS Unit No. 2. The new analysis calculates the non-accident soluble boron concentration to be less than was determined in the Amendment 128 evaluation. Thus, there is no significant reduction in Page 9

Beaver Valley Power Station License Amendment Request Nos. 333 and 204 a margin of safety because of the new analysis and the conclusions of the Amendment 128 dilution evaluation remain valid.

Under accident conditions, the soluble boron needed to maintain klrr below 0.95 with the new storage configurations is less than what is assumed in current analysis. The proposed change does not involve a significant reduction in a margin of safety for accident conditions.

The editorial changes made to the table numbers and the LCO and Surveillance Requirement wording do not impact a margin of safety.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, FENOC concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and, accordingly, a finding of"no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria A review of 10 CFR 50, Appendix A, "for Nuclear Power Plants" (Reference 6), was conducted to determine the impact associated with the proposed change. The General Design Criteria (GDC) were evaluated as follows:

1.

General Design Criterion 2, as it relates to structures housing the facility and the facility itself being capable of withstanding the effects of natural phenomena, such as earthquakes, tornadoes, hurricanes, and floods.

2.

General Design Criterion 4, as it relates to structures housing the facility and the facility itself being capable of withstanding the effects of environmental conditions, external missiles, internally generated missiles, pipe whip, and jet impingement forces associated with pipe breaks, such that safety functions will not be precluded.

3.

General Design Criterion 5, as it relates to shared structures, systems, and components important to safety being capable of performing required safety functions.

4.

General Design Criterion 61, as it relates to the facility design for fuel storage and handling of radioactive materials.

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Beaver Valley Power Station License Amendment Request Nos. 333 and 204

5.

General Design Criterion 62, as it relates to the prevention of criticality by physical systems or processes utilizing geometrically safe configurations.

6.

General Design Criterion 63, as it relates to monitoring systems provided to detect conditions that could result in the loss of decay heat removal capabilities, to detect excessive radiation levels, and to initiate appropriate safety actions.

The new and spent fuel storage racks are designed in accordance with GDC 62 and NUREG-0800. The new fuel storage rack accommodates one third of a core plus 17 spare assemblies. The spent fuel storage pool accommodates the spent fuel rack and the required spent fuel shipping cask area.

The spent fuel racks are arranged so that the spacing between fuel elements cannot be less than that prescribed. Borated water is maintained in the spent fuel pool. Even if fully flooded with unborated water, the spacing and fuel storage configurations ensure keff < 1.0.

The spent fuel storage area, located in the fuel building, is designed to provide a safe and effective means of storing spent fuel.

The Unit No. 2 spent fuel pool also complies with the requirements of the following Regulatory Guides.

1.

Regulatory Guide 1.13, Fuel Storage Facility Design Basis

2.

Regulatory Guide 1.29, Seismic Design Classification

3.

Regulatory Guide 1.115, Protection Against Low-Trajectory Turbine Missiles

4.

Regulatory Guide 1.117, Tornado Design Classification Assessment No change to the UFSAR description of conformance to the GDCs or the listed Regulatory Guides is required as a result of the change proposed in this LAR.

Page 11

Beaver Valley Power Station License Amendment Request Nos. 333 and 204 In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCES

1.

WCAP-1 6518-P/ WCAP-1 6518-NP, "Beaver Valley Unit 2 Spent Fuel Pool Criticality Analysis", Revision 1, May 2006.

2.

WCAP-14416-NP-A, "Westinghouse Spent Fuel Rack Criticality Analysis Methodology", Revision 1, November 1996.

3.

Regulatory Issue Summary (RIS)01-012, "Nonconservatism in Pressurized Water Reactor Spent Fuel Storage Pool Reactivity Equivalencing Calculations," May 18, 2001.

4.

NRC Safety Evaluation Report for Beaver Valley Power Station Unit 2 Amendment 128, letter dated February 11, 2002.

5.

Westinghouse Electric Company Letter, FENOC-00-1 10, "NSAL-00-015, "Axial Bumup Shape Reactivity Bias," November 2000.

6.

10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants."

Page 12

Attachment A Beaver Valley Power Station Proposed Technical Specification Changes License Amendment RequestANos. 333 and 204 The following is a list of the affected pages:

3.7.14-1 3.7.14 -2 3.7.14-3 3.7.14-4 3.7.14-5 3.7.14-6 3.7.14-7

Spent Fuel Pool Storage 3.7.14 3.7 PLANT SYSTEMS 3.7.14 Spent Fuel Pool Storage LCO 3.7.14 APPLICABILITY:

The-eombinatiof-initiatenrirhment-and-bumup-of-eEach fuel assembly stored in the spent fuel storagepool shall be within the limits specified in Wable3,1-41 TitU,(* !),

ae h

3 Whenever any fuel assembly is stored in the spent fuel storage pool.

I ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Requirements of the A.1 LCO not met.

- NOTE -

LCO 3.0.3 is not applicable.

Initiate action to move the Immediately noncomplying fuel assembly to a location that compiess with 5-6b1673.7.1 4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.14.1 Verify by administrative means the initial-enriGhment Prior to storing andrb

_fu the-fuel assembly is in accordance with the fuel assembly j1able 3.7.4A

)Unit 1, a be-TRM21h in the spent fuel JjffM4!TfU~fiitF2*T ij2&ffP.

storage pool.

Beaver Valley Units I and 2 3.7.14-1 Amendments--L-I

Spent Fuel Pool Storage 3.7.14

?U.i t IJI S. 6e ht -Fuel Pool 'Storage)

Fuel Assembly Minimum Burnup versus U-235 Initial Enrichment for Storage in Spent Fuel Rack Regions 1, 2, and 3 Region 3 Region 2 Region I Nominal Assembly Discharge Assembly Discharge Assembly Discharge Enrichment Burnup Burnup Burnup (w/o U-235)

(MWD/MTU)

(MWD/MTU)

(MWD/MTU) 2.0 0

2585 0

2.348 0

7911 (calculated) 0 2.5 1605 9551 0

3.0 6980 15784 0

3.5 11682 21643 0

4.0 16239 27260 0

4.5 20672 33710 0

5.0 25000 40000 0

NOTES:

Region 2:

The data in the above Table may be interpreted linearly or may be calculated by the conservative equation below. This equation provides a linear fit to the design bumup limits.

Minimum Bumup, MWD/MTU = 12,100

• E% - 20,500 Where E = Enrichment (E < 5%)

Region 3:

The data in the above Table may be interpreted linearly or may be calculated by the conservative equation below. This equation provides a best fit to the design bumup limits.

Minimum Bumup, MWD/MTU = -480 * (E%) 2 + 12,900

• E% - 27,400 Where E = Enrichment (E 5 5%)

Beaver Valley Units 1 and 2 3.7.14 -2 Anjenjftents

Spent-Fue Pool Storage Tim AM" F-uekAssembly-Minimum-Burnpv~ersus-U-2ni5aLnitiao ihment-or-Storagein--Spent-F-ue[-Rao~k Regions4-,2,-and-3 Region-3 Region-2 Region-4 Nominal 4-out-of-4 3-out-of-4 2-out-of-4 Enrichment Bumup Checkerboard Checkerboard (w/o-U-235)

(MWD/MTU)

Bumup Burnup (MWDIMTU)

(MWD/MTU)

-179 0

0 0

2-0 4646 0

0 2.-2 4629 0

0 2A4 7295 0

0 2.6 967-7 0

0 2-8 4-477 4-7-98 0

30 4-3995 3556 0

3.2 461442 5268 0

3.4 482-35 6940 0

20349 8581 0

3-8 22443 40498 0

4;0 24503 41800 0

4.2 26549 43394 0

4.4 28492 44979 0

4-6 30428 46552 0

4.8 32329 481-40 0

6,0 34204 496-50 0

NOTE:

i O

a i

IQ i

t 12-Mmar-nteDat on-i-vIes-Gonservative rests r

j..................

m II m i od g

mu n r-e e J

Spent Fuel PoolStorage 32-1A EuelAssembly Minimum Burnup versus-Initial Enrichment for the "All-Cell" Storag1eCioflfuratiofl nitalEnrichment Bump 1.8U56 0

4M 23.92 5MOlOD 4

Any*uy ranmM ay-ab-o1adedahe int erfacewith-angtheLconhiguratibm Nohte thath-e_

ukde-minmum-assembybumup_(in MWD/MTU Mranab.oaie initial enrichment ma*ybealJated-usingjhe-equation below, where E% is the assemblyjinial enrichment in weight percent U-_235.

Assembty_.Bumunp = 78.116(E%) 3 - 1002.647(E%) 2+ 14871.032(E%)_24649M599 tMIIe,., i In;4c~ 4 ~nA )

. 7 IA -'

Amrnrlnin I

LdyGLY~t...,YS+._£

-J.I

. i*l tJ r*n II llI uII

pMent uel Pool Stolage 31ZAA 4~~~

4 Euel Assembly Minimum Bumup versus Initial Endchment for the feDssembles inthe "x30" SloragPeCpnfiLqotion Initial

_u__up__

Enichmen 5

r 15vyr

_20w d c90Y daay daca decay 1.194 0

_0

_Q Mm06 29.330 ZA 4O03_

3_2_

36.835

-Only--de pletedueLa ssemb blP.~a~~._ded-athe_,i n te rfacw~t h-a not he r cnfigur~atio[

loe that the required minimum asemb[yvbimup (in MWD/MTU) for an assembly-ofa-giyven initial enrichm

ybe caklulated usingth~e-e~quatmieo w, wovhere,_Effjs~ke-a~s~emb* initial enrichment in wei-ght percent U-235.

.AssemrbtyB umu p_(0_yre-cay -)_226-34_6(EF.*)I=_3

_22.*515 (EO.%) 2 _*29]_7_0012.( F%-O~)_=_3 07-5,9-089 Assemblyumup_(5yLdecayl =A41L.594A(E%)3 -

• F 2 +/-__35 MZlE

- 3118.9 AssemblyBumup_(10_yrudecay) -_19-829(E_%)

3 -2,.9A8.038(FO6A%)2__2432920(_.%)

-_25290.5A5 AssemblyBumupUlS-yLdecay) -=_229-8_8(E_%) -309-_2064(E-)2 +

__2__08.,29_8(F.)--251__3 A lembly Bmvup_ 2 erady)_=_2_12.385 (

_M)-22.___(

.1 14")

7274A A

A nanrln4 nte I

LJvcI V~I V pi I~Y~JLIIA~

I cii

• L.

.~.

. i-v -

-y

,-~. I

_Spent fuel Pool Storage 3-7-A 3#4 a Fuel Assembly Minimum Burnup versus Initial Enrichment for the depleltedassemblies in the "l -out-of-4 5.0 w/o at 15,000 MWD/MTU" StorageCnoimuration iaLEnnidiment 3uu 1.5_6_

0 3)0~O 2o.160 law0 2-06-0

ý-

5.000 43=67

_Ony-depeteA~teLassamble-s-maydbeJoadedaLt hentdefac*wlla LcpnfL urati-.

Moteihatlhleu.reudminimum assembly-b-umup (in MWD/MTU) for aMas,,mblynfaghven initialenrichment may_.becalculated usinAthe-equationmbelow, wherefEis te asseavinftial enrichment in weiaht Dercent U-235.

Assembly Bumup = 259.098(E%)3 - 3159.653(E%)2+ 24337.852(

- 31412.160 PI nlllr \\ll I Inrelý 4 In I)

"4 7 IA_ -

Amendments__/_

I Ingh, 4 ~nl )

-~ 7 4A Amendrnentsll

Spent Fuel Pool Storage aI4 FM~'

86d EuejlAssPemblMinimum Burnup versus IniiaI Enrichment for the deped assemblies in the "l-out-of-4 3.85 w/o Fresh with IFBA S-torageC-oquration Initial Enrichment Bump Jwto U-2_35 tMWD/MTU) 1.27_9 P

3-MD 242=5 52,205 Onydepdetex fuel assemblies may be loaded at the interface with another conf'muratboA Notejhat the required minimum assembhly.

p (in MWD/MTU)foLan-assembWyoLa.qhien initial enrichment may be calculated-usingqheegution below, whteie-EhJse..assem1~y initial enrichmentinweightpercentU-2_5.

AssembJumup=349.1t(E%

-4422.547(E%)

2 + 30258.6ME

-(32203-*_1 RAMIlAr \\/-n A 9

'A7 1A.-

A m,'nrlmganf' Re~~,or ~/~IIc~i, I Inifc~ I ~inrI 9 7 IA A rn~nIn,~n*c~

I

Spent Fuel Pool Storaae 3.714 i A Minimum Number of IFBAs versus Initial Enrichment for the "l-out-of-4 3.85 wlo Fresh with IFBA" Storame-Caguration Initial Enrichment fW&_U:

INumberoLUEBAs z

4-5_

3o 5 M631 Note that the-rauired miniu*um number of1IBApinssattion ofagiven initial enrichmeJFt may be-calculatedusin1the..eq uation-belowt where E% is-tie-assemblyinitiaLenidch mentn w-eiLqh enLU-_23 Number of IFBA Pins = 15.444(E%)3- _187.380(E%)2 + 800.53(E 11-* 5967 Required Number of IFBA pins is for 120 inch IFBA with 1.5X B-10 loadin*.

R~mvr Vllp=v I nitz I mnl 9

.'A 7 1A-7 Aminnrfmpnt--

/

I Inifc~ I ~.nd 9 714-7 Am~nrIm~~nt~

I

Attachment B Beaver Valley Power Station Proposed Technical Specification Bases Changes License Amendment Request Nos. 333 and 204 The following is a list of the affected pages:

B 3.7.14 - 1 B 3.7.14 - 2 B 3.7.14 - 3 B 3.7.14 - 4 B 3.7.14 - 5

Provided forInformation Only.

Provided for nfoSpent Fuel Pool Storage B 3.7.14 B 3.7 PLANT SYSTEMS B 3.7.14 Spent Fuel Pool Storage BASES BACKGROUND The spent fuel storage racks contain storage locations for 1627 fuel assemblies (Unit 1) and 1088 fuel assemblies (Unit 2). The racks are designed to store Westinghouse 17X17 fuel assemblies with nominal enrichment up to 5.0 weight percent.

For Unit 1. tlhe spent fuel storage racks are divided into three regions with different fuel bumup-enrichment limits associated with each region.

Fuel assemblies may be stored in any location.asseif.,dinL*bI 3-7-14-.L provided the fuel burnup-enrichment combinations are within the limits specified for the associated storage rack region in the accompanying LCO.

For Unit 1, the spent fuel storage racks are constructed, in part, from a boron carbide and aluminum-composite material with the trade name "Boral." The Boral material provides a neutron absorbing function to maintain the stored fuel in a subcritical condition. Therefore, soluble boron is not required in the Unit 1 spent fuel pool to maintain the spent fuel rack multiplication factor, keff, -< 0.95 when the fuel assemblies are stored in the correct fuel pool location in accordance with the accompanying LCO and no fuel movement is in progress (i.e., the pool is in a static condition). The fact that soluble boron concentration is not required to maintain the Unit I spent fuel rack multiplication factor, keff,

< 0.95 is confirmed in Holtec Report HI-92791 (Ref. 1). However, a boron concentration is maintained in the Unit 1 spent fuel pool to provide negative reactivity for postulated accident conditions (i.e., a misplaced fuel assembly resulting from fuel movement) consistent with the guidelines of ANSI 16.1-1975 (Ref. 2) and the April 1978 NRC letter (Ref. 3). The required Unit 1 spent fuel pool boron concentration for a reactivity excursion due to accident conditions is 1050 ppm.

Safe operation of the Unit 1 spent fuel pool with no movement of assemblies may therefore be achieved (without reliance on soluble boron) by controlling the location of each stored fuel assembly in accordance with the accompanying LCO.

For Unit 2. spent fuel storage is dictated by different storage configurations associated with fuel burnup. enrichment, decay, interface and Integral Fuel Burnable Absorber (IFBA) requirements. Fuel assemblies must be stored in repeating arrays of the configurations specified in Tables 3.7.14-2 througkh 3-17.14-6. asappkable,_specified-in Beaver Valley Units 1 and 2 B 3.7.14 - 1

-- 0-412-0351 -033L2D-I

Provided for Information Only.

Spent Fuel Pool Storage3.7.14 BASES BACKGROUND (continued)

Wg.tinghouse 17 x 17 Standardjuel-assemblies with nominal enrichments less than or equal to 1.856 w/o U-235 can be stored in any cell location. This configuration is designated as "All-Cell". Fuel assemblies with initial nominal enrichments areaterAhan these limits must-sa*

bumpbun re.quirement as shown in Table-3.7.14-2.

Westinghouse 17 x 17 standa Melassemblies can be stored in a 3x3 matrix of tokrage cell with eigbLstoiage ellcations formin'Ta d.ri ol-dep assemblies that surround a 5.0 wlo fresh fuel assembly hisconfitguratigais designatedasx&h Te ded fJueLassemblies musthave-aniattiaLnomi enrichment of less than or auaLto 1.194 w/o U-235, or satisfy.arminimum burnum requirement for highrinital enrichments asashown in Table3.74-3.

The bumupueguirements for the depMetdassemblies in thiscnf*lguration canbe rduce crd itin g[decaytire.

MeStinghouse 171stanariddJueassembtas an be stored in a_2x2_matdx.of storage ith a 5.0 w/o U_235nominal initial-enrichmenfuel-assembly haynQabUQ of atlieasl10 DMTUcipyngastoageeU ation and-devleled fuel assemblies occupying the three remainingJocations. This monfiguration is designated as l-out-of-4 5.0 w/o at 15.000 MWD/MTU". The depleted fuel assemblies must have an initial nominal enrichment of less than or equal t.59 wLo U-235,_U satisfy-aiminimu rwburnecuirement for higher initial enrichments-as shown in Table3.I7A.44.

Westinghouse 17 x 17 stadarfuelassemblies canbe stored in a 2x~matrk-of storage cells with a 3.85 w/o U-235 nominal initial enrichment fresh fuel assembly ccupying-at geceLLcatinn.anddepleted fuel assemblies pccupying the three remaining locations. This configuration is designated-as "l-out-of-4 3.85 w/o with IFBA". The depleted fuel assemblies must have an initial nominal enrichment of less thaniorxeualto 1.279 wlo U-235. or saishfya mnimubumrnunieauirneenf gheriniialendrichmentsasshowniTable 3.7.14-5. The fresh fuel assembly must have an initial nominal enrichment of less than or equal to 3.85 wlo U-235. or must contain a minimum number ofIEBA pins for higher initial enrichments as shown in Table 3.7.14-6.

For Unit 2, spent fuel racks have been analyzed in accordance with the methodology contained in W:AP 11116 NP A (Reýf4),as-supplemented-by Westinghouse--E-ler6GetCmpany-letter-FENO 0

0-440 (Re-.and documented in WCAP-1 6518-P (Ref 4) This methodology ensures the spent fuel rack multiplication factor, ks, is _ 0.95, as recommended by the April 1978 NRC letter (Ref. 3) and ANSI/ANS-57.2-1983 (Ref. 65). The codes, methods, and techniques contained in the methodology are used to satisfy this keff criterion.

Beaver Valley Units I and 2 B 3.7.14 - 2 4--034IM351-M39--M I

Provided for Information Only.

Spent Fuel Pool Storage B 3.7.14 BASES BACKGROUND (continued)

The Unit 2 spent fuel storage racks are analyzed utilizing credit for GheGkerbeard-Gonfiguratiens-, burnup, burmable-absorbers, decay time and soluble boron, to ensure keff is maintained < 0.95, including uncertainties, tolerances, and accident conditions. The Unit 2 spent fuel pool ke, can only be maintained < 1.0incdingtuncedaintiesand tolerances on a 95195 proRbabfityvlc ence level, without crediting soluble boron.

Therefore, the safe operation of the Unit 2 spent fuel pool with no movement of assemblies necessitates both the storage requirements of the accompanying LCO as well as the fuel pool boron concentration requirements of LCO 3.7.16 be met.

I APPLICABLE SAFETY ANALYSES The hypothetical accidents can only take place during or as a result of the movement of an assembly (Ref. M_). For these accident occurrences, the presence of soluble boron in the spent fuel storage pool (controlled by LCO 3.7.16, "Fuel Storage Pool Boron Concentration") prevents criticality in both-regionstie entfuest* agetpaI. By closely controlling the movement of each assembly and by checking the location of each assembly after movement, the time period for potential accidents may be limited to a small fraction of the total operating time.

sthrugh

• mpliance with the accomparinyj LCO and refuelingoDrocedures that cmffmlance with theappojcab~entfelorqgelit analyms¶i is-assured.

For Unit 1, during the remaining time period with no potential for accidents, the operation may be under the auspices of the accompanying LCO without reliance on soluble boron.

For Unit 2, however, when no potential for an accident exists, safe operation of the spent fuel storage pool must include the boron concentration within the limit specified in LCO 3.7.16 as well as the fuel being stored in accordance with the accompanying LCO. The boron concentration specified in LCO 3.7.16=as well as the storage leGatien requirements of the accompanying LCO are necessary to meet the requirement to maintain kf

• 0.95 in the Unit 2 spent fuel pool under normal (i.e., static) conditions. Operation within the storage location requirements of the accompanying LCO with no soluble boron in the Unit 2 spent fuel pool would only maintain ke, < 1.0I.,JcJudJ uncertainties and tolerances on a 95/95 probabilitv/confidence level. In accordance with WCAP-1 6518-P. the interface boundaries between the various storage requirement configurations are maintained such that only the-depleted assemblies are at the boundary.

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

Beaver Valley Units I and 2 B 3.7.14 - 3 4-034/M35L-QnL2--0-3-6 I

40

¶,

I Provided for Information Only.

I Spent Fuel Pool Storage B 3.7.14 BASES LCO For Unit 1, the restrictions on the placement of fuel assemblies within the spent fuel pool, in accordance with Table 3.7.14-1A, in the accompanying LCO, ensures the ke, of the spent fuel storage pool will always remain

< 0.95, assuming the pool to be flooded with unborated water.

For Unit 2, operation within the storage loeation requirements specified in Tables 3.7.14--8-2_th[ough 3.7.14-6. as ap licable.of the accompanying LCO with no soluble boron in the spent fuel storage pool would only maintain kef <1.0JDncludinquncePainties-andioletmnces on a 95/95 pmbability/confidence level. Therefore, Unit 2 must also maintain the spent fuel storage pool boron concentration within the limit specified in LCO 3.7.16=as well as the storage location requirements of the accompanying LCO in order to meet the requirement to maintain kf _<

0.95.

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

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

When the configuration of fuel assemblies stored in the spent fuel storage pool is not in accordance with Table 3.7.14-1A (Unit 1) and-oLTables 3.7.14-4-B2Athough3.L1 4(Unit 2),asaapplicable, the immediate action is to initiate action to make the necessary fuel assembly movement(s) to bring the configuration into compliance with Table 3.7.14-1A (Unit 1), and orTables 3.7.144B2_hrou-gh.3.7.14-a6(Unit 2),as-appJicable.

The Required Actions are modified by a Note that takes exception to LCO 3.0.3. If unable to move irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not be applicable. If unable to move irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the action is independent of reactor operation. Therefore, inability to move fuel assemblies is not sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.7.14.1 REQUIREMENTS This SR verifies by administrative means that the initial enrichment and burnup of the fuel assembly is in accordance with Table 3.7.14-1A (Unit 1) and-oLTables 3.7.14-1-12 through 3.7.14-6 (Unit 2)ap b

in the accompanying LCO. Verification by administrative means may be accomplished through fuel receipt records for new fuel or bumup analysis as necessary in accordance with refueling procedures. The Frequency of prior to storing a fuel assembly ensures that fuel assemblies are stored within the configurations analyzed in the spent fuel criticality analysis.

Beaver Valley Units 1 and 2 B 3.7.14 - 4 1 031/2 035l--G33a--M I

4.

Spent Fuel Pool Storage B 3.7.14 BASES REFERENCES

1.

Holtec Report HI-92791, Rev. 6, "Spent Fuel Pool Modification For Increased Storage Capacity, Beaver Valley Power Station Unit 1,"

April 1992 as supplemented by Letter to the NRC (License Change Request No. 202, Supplement 1, Spent Fuel Pool Rerack) dated June 28, 1993.

2.

ANSI 16.1-1975 (ANS-8.1), Nuclear Criticality Safety In Operations With Fissionable Materials Outside Reactors.

3.

NRC Letter to All Power Reactor Licensees from B. K. Grimes, "OT Position for Review and Acceptance of Spent Fuel Storage and Handling Applications," April 14, 1978.

4.

WCAP 1*116 NP-A-Westinghouse-Spent-F-ue -Raek-Giticality Analysis-Methodology,--Revision4-November-99S

&-Westinghouse-E--leCtric-Go mpany-Letter-,--E-NO G-04!!0,-"NSAL-O0-015,-"AxiaI-Bumup-Shape-Reactivity-Bias,-November-200 7

6.

WCAP-16518-P. "Beaver ValfeyUnit2SpenLEu.LackCriticality Analysis," Revision 1.MayZ0_0

67. ANSI/ANS-57.2-1983,- "Design Requirements for Light Water Reactor Spent Fuel Storage Facilities at Nuclear Power Stations."

87.

UFSAR Section 14 (Unit 1) and UFSAR Section 15 (Unit 2).

Beaver Valley Units 1 and 2 B 3.7.14 - 5 4-M"351-MW--M I