L-2009-247, Issuance of Amendment Regarding Spent Fuel Boraflex Remedy - Supplement 2 to Request for a Change in Implementation Date

Issuance of Amendment Regarding Spent Fuel Boraflex Remedy - Supplement 2 to Request for a Change in Implementation Date

ML093080185
Person / Time
Site:	Turkey Point
Issue date:	10/29/2009
From:	Kiley M Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2009-247
Download: ML093080185 (7)

Text

0 FPL, 10 CFR 50.90 L-2009-247 POWERING TODAY.

EMPOWERING TOMORROW.0 October 29, 2009 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D.C. 20555-0001 Re: Turkey Point Unit 4 Docket No. 50-251 Issuance of Amendment Regarding Spent Fuel Boraflex Remedy Supplement 2 to Request for a Change in Implementation Date

References:

1. Letter from Michael Kiley (FPL) to USNRC, "Implementation Date Change for License Amendments 234 and 229," L-2009-200, September 1, 2009.

2. Letter from Michael Kiley (FPL) to USNRC, "Issuance of Amendment Regarding Spent Fuel Boraflex Remedy - Supplement to Request for a Change in Implementation Date," L-2009-246, October 28, 2009.

3. Letter from K. N. Jabbour (USNRC) to T. F. Plunkett (FPL), Turkey Point Units 3 and 4 -

Issuance of Amendments Regarding Boron Credit in The Spent Fuel Pool (TAC Nos. MA7262 and MA7263), July 19, 2000.

Florida Power and Light Company (FPL) submitted an application for amendment of the Unit 3 and 4 licenses in Reference 1. The application was supplemented by FPL for Unit 4 in Reference 2. This letter provides additional information regarding Unit 4.

In response to a telecon request from the NRC staff, FPL hereby commits to perform our next scheduled Boraflex panel surveillance using the EPRI BADGER (Boron- 10 Areal Density Gauge for Evaluating Racks) neutron attenuation methodology in the Unit 4 spent fuel pool (SFP). The test will occur no later than May 30, 2010. This is consistent with the continued operation of the Unit 4 SFP in accordance with the current Technical Specifications (TS) (attached) reviewed and approved by the NRC in Reference 3, and further will provide additional validation of the EPRI RACKLIFE model for the Unit 4 SFP that is used to predict the extent of Boraflex degradation. Additionally, FPL will provide to the NRC a copy of the vendor's surveillance report within 120 days of completing the surveillance. The attached TS will be effective until implementation of Turkey Point Unit 4 License Amendment No. 229.

RACKLIFE is an industry standard that has been used by several utilities, both PWR and BWR, over many years to both monitor and manage Boraflex degradation in the SFP. RACKLIFE models the key Boraflex dissolution mechanisms in the SFP, modeling and tracking the irradiation history and silica transport of each Boraflex panel in the SFP. The methodology uses essentially a zero dimensional code representing the Boraflex panel, the poison cavity bounded by the surface of the panel and the wrapper plate (that mechanically holds the panel in place), and the bulk water as separate compartments. The an FPL Group company

Florida Power and Light Company L-2009-247 License Amendment Request No. 201 Supplement 2 Page 2 of 2 transport of silica to and from each compartment is represented by a set of rate equations with experimentally established transport coefficients for the dissolution of silica. Given the initial silica and boron carbide concentration in the panel, the rate equations are simultaneously solved for each panel in the pool until the process comes into equilibrium with the silica concentration in the bulk pool water.

The final result is the predicted silica concentration remaining in the Boraflex panel which is correlated to the percentage of boron carbide loss from the panel.

An adjustable escape coefficient accounts for the leakage from the wrapper plate due to manufacturing variability. This coefficient has been adjusted by the code vendor such that the model shows reasonable agreement between the calculated silica concentration and the historical measured concentration.

The projected Boraflex degradation for the Unit 4 SFP as of September 30, 2012 provided in Reference 2 was based on the RACKLIFE methodology briefly described above and applying the historical operating conditions that include fuel storage and transfers to, from, and within the various storage cells of the SFP since the initial in-service date in 1989 to November of this year. The maximum difference in the boron carbide loss over duration of two cycles. (the end of Cycle 22 and end of Cycle 24) predicted by RACKLIFE was doubled and added to that of the panel at end of Cycle 24 having the maximum boron carbide loss. This difference increased by a factor of two provides a conservative representation of the expected increase in degradation between the end of Cycle 24 and September 30, 2012. The projected maximum Boraflex degradation by the requested implementation date for Amendment 229 of September 30, 2012 remains well, above the maximum degradation of Boraflex assumed in the analysis supporting Reference 3 FPL has determined that the additional information provided above does not impact the conclusions of the No Significant Hazards Consideration determination in Reference 1.

If you have any questions or require additional information, please contact Robert Tomonto at 305-246-7327.

I declare under penalty of perjury that the foregoing is true and correct.

Very truly yours, 10/29/2009 Executed on Michael Kiley Vice President - Turkey Point Nuclear Plant

Attachment:

Technical Specifications for Spent Fuel Storage cc: Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant USNRC Project Manager for Turkey Point Mr. William Passetti, Florida Department of Health

Attachment Florida Power and Light Letter L-2009-247 Issuance of Amendment Regarding Spent Fuel Boraflex Remedy Supplement 2 to Request for a Change in Implementation Date Current Technical Specification Pages for Spent Fuel Storage

REFUELING OPERATIONS 3/4.9.14 SPENT FUEL STORAGE LIMITING CONDITION FOR OPERATION 3.9.14 The following conditions shall apply to spent fuel storage:

a. The maximum enrichment loading for the fuel assemblies in the spent fuel racks shall not exceed 4.5 weight percent of U-235.

b. The minimum boron concentration in the Spent Fuel Pit shall be 1950 ppm.

c. Storage in Region II of the Spent Fuel Pit shall be further restricted by burnup and enrichment limits specified in Table 3.9-1.

APPLICABILITY: At all times when fuel is stored in the Spent Fuel Pit.

ACTION:

a. With either condition a, or c not satisfied, suspend movement of additional fuel assemblies into the Spent Fuel Pit and restore the spent fuel storage configuration to within the specified conditions.

b. With boron concentration in the Spent Fuel Pit less than 1950 ppm, suspend movement of spent fuel in the Spent Fuel Pit and initiate action to restore boron concentration to 1950 ppm or greater.

SURVEI LLANCE REQUIREMENTS 4.9.14 The boron concentration of the Spent Fuel Pit shall be verified to be 1950 ppm or greater at least once per month.

TURKEY POINT - UNITS 3 &4 3/4 9-15 AMENDMENT NOS. 149 AND 144

TABLE 3.9-1 SPENT FUEL BURNUP REQUIREMENTS FOR STORAGE IN REGION II OF THE SPENT FUEL PIT Initial Discharge Burnup w/o MWD/MTU 1.6 0.0 1.80 3706 2.00 7459 2.20 9724 2.40 12582 2.60 15338 2.63 15914 2.80 17994 3.00 20548 3.25 23312 3.40 25354 3.60 27605 3.88 30256 4.00 31804 4.20 33752 4.40 35599 4.50 36746 Linear interpolation between values may be used for intermediate points.

TURKEY POINT - UNITS 3 & 4 3/4 9-16 AMENDMENT NOS. 206 AND 200

DESIGN FEATURES 5.5 FUEL STORAGE 5.5.1 CRITICALITY 5.5.1.1 The spent fuel storage racks are designed to provide safe subcritical storage of fuel assemblies by providing sufficient center-to-center spacing or a combination of spacing and poison and shall be maintained with:

a. keff equivalent to less than 1.0 when flooded with unborated water, which includes a conservative allowance for uncertainties as described in UFSAR Appendix 14D.

b. A keff equivalent to less than or equal to 0.95 when flooded with water borated to 650 ppm water, which includes a conservative allowance for uncertainties as described in UFSAR Appendix 14D.

c. A nominal 10.6 inch center-to-center distance for Region I and 9.0 inch center-to-center distance for Region II for the two region spent fuel pool storage racks. A nominal 10.1 inch center-to-center distance in the east-west direction and a nominal 10.7 inch center-to-center distance in the north-south direction for the Region I cask area storage rack.

d. The maximum enrichment loading for fuel assemblies is 4.5 weight percent of U-235.

5.5.1.2 The racks for new fuel storage are designed to store fuel in a safe subcritical array and shall be maintained with:

a. A nominal 21 inch center-to-center spacing to assure keff equal to or less than 0.98 for optimum moderation conditions and equal to or less than 0.95 for fully flooded conditions.

b. Fuel assemblies placed in the New Fuel Storage Area shall contain no more than 4.5 weight percent of U-235.

TURKEY POINT - UNITS 3 &4 5-5 AMENDMENT NOS. 226 AND 222

DESIGN FEATURES 5.5.1.3 Credit for burnup is taken in determining placement locations for spent fuel in the two-region spent fuel racks. Administrative controls are employed to evaluate the burnup of each spent fuel assembly stored in areas where credit for burnup is taken. The burnup of spent fuel is ascertained by careful analysis of burnup history, prior to placement into the storage locations. Procedures shall require an independent check of the analysis of suitability for storage. A complete record of such analysis is kept for the time period that the spent fuel assembly remains in storage onsite.

DRAINAGE 5.5.2 The spent fuel storage pit is designed and shall be maintained to prevent inadvertent draining of the pool below a level of 6 feet above the fuel assemblies in the storage racks.

CAPACITY 5.5.3 The spent fuel pool storage racks are designed and shall be maintained with a storage capacity limited to no more than 1404 fuel assemblies in two region storage racks, and the cask area storage rack is designed and shall be maintained with a storage capacity limited to no more than 131 fuel assemblies. The total spent fuel pool storage capacity is limited to no more than 1535 fuel assemblies.

5.6 COMPONENT CYCLIC OR TRANSIENT LIMIT 5.6.1 The components identified in Table 5.6-1 are designed and shall be maintained within the cyclic or transient limits of Table 5.6-1.

TURKEY POINT - UNITS 3 & 4 5-6 AMENDMENT NOS. 226 AND 222