ML020640476

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Part 1 of 2, San Onofre Nuclear Generating Station, Units 2 & 3, Amendment Application Numbers 215 & 200 Proposed Change Number (PCN) 536 Request to Revise Technical Specifications to Create & Implement Fuel Storage Program
ML020640476
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 02/22/2002
From: Nunn D
Southern California Edison Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
PCN 536
Download: ML020640476 (139)


Text

SOUTHERN CALIFORNIA* Dwight E. Nunn EDISON Vice President An EDISON INTERNATIONAL" Company February 22, 2002 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

Subject:

San Onofre Nuclear Generating Station Units 2 and 3 Docket Nos. 50-361 and 50-362 Amendment Application Numbers 215 and 200 Proposed Change Number (PCN) 536 Request to Revise Technical Specifications to Create and Implement the Fuel Storage Program

Dear Sir or Madam:

Pursuant to 10CFR50.90, Southern California Edison (SCE) hereby requests Amendment Application Numbers 215 and 200, which consist of PCN 536. PCN 536 proposes to revise Technical Specifications 3.7.17, "Fuel Storage Pool Boron Concentration," 3.7.18, "Spent Fuel Assembly Storage," and 4.3, "Fuel Storage" and to create 5.5.2.16, "Fuel Storage Program." This proposed change will revise the minimum allowed boron concentration of the spent fuel pool and implement a fuel storage program to allow credit for soluble boron in place of Boraflex. Changes to the associated Bases are made for consistency and are included for information only. SCE has evaluated these requests under the standards set forth in 10 CFR 50.92(c) and determined that a finding of "no significant hazards consideration" is justified.

The requested approval date is the date SCE expects the results from the next regularly scheduled Boraflex coupon surveillance. Although SCE expects the coupon surveillance to yield satisfactory results, the implementation of these amendments requires a significant amount of fuel to be relocated to other spent fuel storage locations, as well as procedure changes and program implementation. Therefore, SCE requests approval of the proposed amendments by July 9, 2002, and that once approved, the amendments be implemented within 30 days of approval or July 9, 2002, whichever is later.

P.O. Box 128 San Clemente, CA 92674-0128 949-368-1480 Fax 949-368-1490

Document Control Desk February 22, 2002 SCE is making no formal commitments that would derive from NRC approval of the proposed amendment.

If you have any questions or require additional information, please contact Mr. Jack Rainsberry at (949) 368 7420.

Sincerely, I Enclosures

1. Notarized Affidavits
2. Licensees Evaluation Attachments A. Existing Technical Specification Pages, Unit 2 B. Existing Technical Specification Pages, Unit 3 C. Proposed Technical Specification Pages, Redline and Strikeout, Unit 2 D. Proposed Technical Specification Pages, Redline and Strikeout, Unit 3 E. Proposed Technical Specification Pages, Unit 2 F. Proposed Technical Specification Pages, Unit 3 G. Proposed Bases Pages (For Information Only), Unit 2 H. Proposed Bases Pages (For Information Only), Unit 3 I. Proposed Fuel Storage Program J. Spent Fuel Pool Dilution Analysis K. Spent Fuel Pool Criticality Analysis cc: E. W. Merschoff, Regional Administrator, NRC Region IV C. C. Osterholtz, NRC Senior Resident Inspector, San Onofre Units 2 and 3 L. Raghavan, NRC Project Manager, San Onofre Units 2 and 3 S. Y. Hsu, Department of Health Services, Radiologic Health Branch

ENCLOSURE 1 NOTARIZED AFFIDAVITS

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA ))

EDISON COMPANY, ET AL. for a Class 103 Docket No. 50-361

)

License to Acquire, Possess, and Use )

a Utilization Facility as Part of Amendment Application

) No. 215 Unit No. 2 of the San Onofre Nuclear )

Generating Station SOUTHERN CALIFORNIA EDISON COMPANY et al., pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 215. This amendment application consists of proposed change No. NPF-10-536 to Facility Operating License NPF-10. Proposed change No. NPF-10-536 is a request to revise Technical Specification 3.7.17, "Fuel Storage Pool Boron Concentration," 3.7.18, "Spent Fuel Assembly Storage," and 4.3, "Fuel Storage," and to create 5.5.2.16, "Fuel Storage Program." This proposed change will revise the minimum allowed boron concentration of the spent fuel pool and implement a Fuel Storage Program to allow credit for soluble boron in place of Boraflex.

State of California County of San Diego 2 lhoiday of Subscribed and sworn to (or affirmed) before me this Vice President

/1 I

Commission #1 196482 110 *8*

i *Notry.

i \*:* My omm E~imsOct14,00 Pubic- California Son Diego County

/

(9 0

' Notary Public

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA )

EDISON COMPANY, ET AL. for a Class 103 ) Docket No. 50-362 License to Acquire, Possess, and Use )

a Utilization Facility as Part of ) Amendment Application Unit No. 3 of the San Onofre Nuclear ) No. 200 Generating Station )

SOUTHERN CALIFORNIA EDISON COMPANY et al., pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 200. This amendment application consists of proposed change No. NPF-1 5-536 to Facility Operating License NPF-1 5. Proposed change No. NPF-15-536 is a request to revise Technical Specification 3.7.17, "Fuel Storage Pool Boron Concentration," 3.7.18, "Spent Fuel Assembly Storage," and 4.3, "Fuel Storage," and to create 5.5.2.16, "Fuel Storage Program." This proposed change will revise the minimum allowed boron concentration of the spent fuel pool and implement a Fuel Storage Program to allow credit for soluble boron in place of Boraflex.

State of California County of San Diego Subscribed and sworn to (or affirmed) before me this ý1XC(day 9

of B y: =,

Dwight E. Nunn Vice President MARIANE SANCHEZ Commission #I 1964a2 Notcry Public - Calffornia

-San Diego Eqp*Oct1]4, County-20,2 lil-A Public

[*mCanrn.

Enclosure 2 LICENSEE'S EVALUATION PCN 536 SPENT FUEL POOL STORAGE WITH NO BORAFLEX AND CREDIT FOR SOLUBLE BORON SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 SECTION PAGE 1.0 INTRO DUCTIO N ................................................. 2

2.0 PROPOSED CHANGE

............................................ 2 3.0 BAC KG RO UND .................................................. 4

4.0 TECHNICAL ANALYSIS

........................................... 4 5.0 REGULATORY SAFETY ANALYSIS .................................. 6 5.1 No Significant Hazards Consideration ............................ 6 5.2 Applicable Regulatory Requirements/Criteria...................... 9 5.3 Adm inistrative Controls ...................................... 11 5.4 C onclusion ............................................... 11

6.0 ENVIRONMENTAL CONSIDERATION

............................... 12 7.0 R EFERENC ES ................................................. 12 8.0 ATTACHMENTS A. Existing Technical Specification Pages, Unit 2 B. Existing Technical Specification Pages, Unit 3 C. Proposed Technical Specification Pages, Redline and Strikeout, Unit 2 D. Proposed Technical Specification Pages, Redline and Strikeout, Unit 3 E. Proposed Technical Specification Pages, Unit 2 F. Proposed Technical Specification Pages, Unit 3 G. Proposed Bases Pages (For Information Only), Unit 2 H. Proposed Bases Pages (For Information Only), Unit 3 I. Proposed Fuel Storage Program J. Spent Fuel Pool Dilution Analysis K. Spent Fuel Pool Criticality Analysis

Enclosure 2 Licensee Evaluation Page 2 of 12

1.0 INTRODUCTION

The proposed changes would revise the Technical Specification (TS) requirements for spent fuel storage to remove credit for use of Boraflex, to take credit for soluble boron, to increase the required concentration of soluble boron, and to create a Technical Specification to control the Fuel Storage Program.

This is a request to revise the following San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 Technical Specifications:

Section 3.7.17, "Fuel Storage Pool Boron Concentration" Section 3.7.18, "Spent Fuel Assembly Storage" Section 4.3, "Fuel Storage" Section 5.5.2.16, "Fuel Storage Program" (New)

2.0 PROPOSED CHANGE

TS 3.7.17 Fuel Storage Pool Boron Concentration LCO 3.7.17 is revised to increase the minimum boron concentration from 1,850 to 2,000 parts per million (ppm). The frequency of verification (7 days) is not changed. Currently, soluble boron is not credited in determining fuel storage requirements used to maintain Keff. However, with the anticipated loss of Boraflex a minimum concentration of soluble boron will be required to maintain Keff to _*0.95. The increase in the TS required concentration from 1,850 to 2,000 ppm ensures that there is no credible boron dilution event that would cause Kef to exceed 0.95. A final boron concentration of 970 ppm following a boron dilution accident would be acceptable. Conservatively, SCE has established a limit for final boron concentration following a boron dilution accident of 1,700 ppm. The difference between 970 ppm (required for Keff _<0.95, non-accident conditions) and 1,700 ppm (assumed in the boron dilution analysis) is discretionary margin. To support the stricter controls being implemented by proposed TS 3.7.18, the applicability of TS 3.7.17 is being expanded to whenever a fuel assembly is stored in the fuel storage pool, and as a result Action A.2.2 is no longer applicable and is being deleted.

TS 3.7.18 Spent Fuel Assembly Storage LCO 3.7.18 is completely revised, and Figures 3.7.18-1 and 3.7.18-2 are deleted.

Specific storage requirements for SONGS Units 1, 2, and 3 fuel assemblies stored in Units 2 and 3 Spent Fuel Pools (SFP) are deleted and replaced with reference to Technical Specification Section 5.5.2.16, "Fuel Storage Program."

Currently the Boraflex in the SFP racks limits Keff to _<0.95 with minimal limitations on fuel assembly initial enrichment and burnup storage location criteria. The anticipated future loss of Boraflex requires additional storage requirements, which are more stringent than those currently in place. A Fuel Storage Program placed in Section 5.0 "Administrative Controls" best serves to control these requirements.

Enclosure 2 Licensee Evaluation Page 3 of 12 TS 4.3.1 Criticality Sub-section 4.3.1.1, is revised as follows.

Item (a) is revised to clarify that the maximum U-235 enrichment of 4.80 weight percent is a NOMINAL value. Fabrication uncertainties are explicitly accounted for in the criticality analysis.

Items (b) through (i) are deleted and replaced with new items (b) through (f).

(b) keff < 1.0 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR; (c) ke, < 0.95 if fully flooded with water borated to 1700 ppm, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR; (d) A nominal 8.85 inch center to center distance between fuel assemblies placed in Region II; (e) A nominal 10.40 inch center to center distance between fuel assemblies placed in Region I; and (f) Units 1, 2, and 3 fuel assemblies shall be stored in accordance with Technical Specification 5.5.2.16, "Fuel Storage Program."

Items (b) and (c) above incorporate new Keff requirements to be implemented as a result of the anticipated loss of Boraflex. Items (d) and (e) above are identical to the current requirements of TS 4.3.1(c) and 4.3.1(d). Item (f) above provides a reference to the proposed TS 5.5.2.16, "Fuel Storage Program," which contains expanded fuel storage requirements which will replace current TSs 4.3.1 (e), 4.3.1 (f), 4.3.1 (g), 4.3.1 (h), and 4.3.1(i).

TS 5.5.2.16 Fuel Storage Program This Section creates the requirement to maintain and implement a Fuel Storage Program. The program must be approved by the NRC, and is included in this PCN as Attachment I, for review and approval.

Changes To TS Bases (included for information only)

Changes to the Bases of TS 3.7.17 and TS 3.7.18 are made for consistency with the proposed changes described above. They are provided in Attachments G and H for information only.

Enclosure 2 Licensee Evaluation Page 4 of 12

3.0 BACKGROUND

The spent fuel storage racks at San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 consist of two storage regions. Region I is generally reserved for temporary storage of new fuel or partially irradiated fuel which does not qualify for Region II storage. Region Il is generally used for normal, long term storage of permanently discharged fuel that has achieved qualifying burnup levels. As originally installed and currently licensed, both regions use Boraflex, a neutron absorbing material. Boraflex consists of fine boron carbide particles distributed in a polymeric silicone encapsulant.

The spent fuel storage racks at SONGS Units 2 and 3 are licensed to store two fuel assembly types:

(1) 16x16, Zircaloy cladding, Combustion Engineering fuel assemblies with a maximum nominal enrichment of up to 4.80 w/o (2) 14x14, Stainless Steel cladding, Westinghouse fuel assemblies (transhipped from Unit 1) with a maximum nominal enrichment of up to 4.00 w/o Erosion/dissolution of Boraflex in Pressurized Water Reactor (PWR) spent fuel pool racks is an industry-wide problem. Silica levels (an indicator of Boraflex dissolution) have been increasing in the SONGS Units 2 and 3 spent fuel pools and are currently about 6 ppm.

Although there is currently sufficient Boraflex, the spent fuel storage rack criticality analyses have been redone assuming no Boraflex. Assuming no Boraflex for SONGS Units 2 and 3 will totally eliminate any Boraflex concerns in the future, and monitoring programs will not be needed to ensure that an adequate amount of Boraflex is always present.

Consistent with other applications approved by the NRC, Southern California Edison (SCE) proposes to take credit for soluble boron in the spent fuel pool water.

4.0 TECHNICAL ANALYSIS

The results of criticality, boron dilution, radiological, decay heat, and structural/seismic analyses show that SONGS Units 1, 2, and 3 fuel assemblies can be safely stored in the SONGS Units 2 and 3 spent fuel racks assuming no Boraflex is present and taking credit for soluble boron.

The maximum nominal fresh enrichment of SONGS Units 2 and 3 fuel assemblies is 4.8 w/o. The SONGS Units 2 and 3 fuel assemblies are 16x16 and have zircaloy cladding.

The maximum nominal fresh enrichment of SONGS Unit 1 fuel assemblies is 4.0 w/o.

The SONGS Unit 1 fuel assemblies are 14x14 and have stainless steel cladding.

Enclosure 2 Licensee Evaluation Page 5 of 12 Assuming no Boraflex, fuel storage patterns have been identified and analyzed in the criticality report (Attachment K) such that:

(1) Under normal conditions, the neutron multiplication factor, Keff, is less than 1.0, including all uncertainties (95/95 probability/confidence level), when the storage racks are flooded with unborated water.

(2) Under normal conditions, the neutron multiplication factor, Keff, is less than 0.95, including all uncertainties (95/95 probability/confidence level), when the storage racks are flooded with borated water at 970 ppm.

(3) Under accident conditions, the neutron multiplication factor, Keff, is less than or equal to 0.95, including all uncertainties (95/95 probabilty/confidence level), when the storage racks are flooded with borated water at 1,700 ppm.

Assuming 2,000 ppm soluble boron in the spent fuel pool water, a boron dilution analysis (Attachment J) shows that it is not credible for the soluble boron concentration to fall below 1,700 ppm.

One-thousand-seven-hundred ppm is the required soluble boron for the fuel mishandling accident. One is not required to assume two unlikely, independent, concurrent events to ensure protection against a criticality accident. Thus, a final boron concentration of 970 ppm following a boron dilution accident would be acceptable. Conservatively, SCE has established a limit for final boron concentration following a boron dilution accident of 1,700 ppm. The difference between 970 ppm (required for Keff _ 0.95, non-accident conditions) and 1,700 ppm (assumed in the boron dilution analysis) is discretionary margin.

Previous decay heat and radiological analyses are not changed by the presence or absence of Boraflex in the spent fuel racks and taking credit for soluble boron.

Previous structural/seismic analyses are not changed by the presence or absence of Boraflex in the spent fuel racks, and stainless steel or aluminum guide tube inserts. The existing structural/seismic analyses performed for SONGS Units 2 and 3 spent fuel racks are conservative in the loadings of the storage cells and the results bound stainless steel or aluminum guide tube inserts (rodlets).

Two detailed reports are attached in Attachments J and K:

(Attachment J) Spent Fuel Pool Dilution Analysis, December 2001 (Attachment K) Spent Fuel Pool Criticality Analysis (With No Borafex And Credit For Soluble Boron), Revision 0, November 2001

Enclosure 2 Licensee Evaluation Page 6 of 12 The replacement of Figures 3.7.18-1 and 3.7.18-2 with Section 5.5.2.16 is an administrative change, not a technical change. This change maintains NRC control as Section 5.5.2.16, "Fuel Storage Program," is part of the Technical Specifications, and the Fuel Storage Program will be uniquely identified in Section 5.5.2.16 such that updates to the Fuel Storage Program will require NRC approval.

Without Section 5.5.2.16, Technical Specification 3.7.18, "Spent Fuel Assembly Storage," would need to change from its current 3 pages to approximately 50 pages.

SCE believes that creating Section 5.5.2.16 is consistent with the technical specification improvement philosophy and is consistent with other Section 5 programs that are existing or are being considered by the NRC and the industry.

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration

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

NO.

Dropped Fuel Assembly There is no significant increase in the probability of a fuel assembly drop accident in the spent fuel pool when assuming a complete loss of the Boraflex panels in the spent fuel pool racks and considering the presence of soluble boron in the spent fuel pool water for criticality control.

The presence of soluble boron in the spent fuel pool water for criticality control does not increase the probability of a fuel assembly drop accident. The handling of the fuel assemblies in the spent fuel pool has always been performed in borated water, and the quantity of Boraflex remaining in the racks has no affect on the probability of such a drop accident.

Southern California Edison (SCE) has performed a criticality analysis which shows that the consequences of a fuel assembly drop accident in the spent fuel pool are not affected when considering a complete loss of the Boraflex in the spent fuel racks and the presence of soluble boron. The rack Keff remains less than or equal to 0.95.

Enclosure 2 Licensee Evaluation Page 7 of 12 Fuel Misloading There is no significant increase in the probability of the accidental misloading of spent fuel assemblies into the spent fuel racks when assuming a complete loss of the Boraflex panels and considering the presence of soluble boron in the pool water for criticality control. Fuel assembly placement will continue to be controlled pursuant to approved fuel handling procedures and will be in accordance with the Technical Specification Section 5.5.2.16, "Fuel Storage Program," which will specify spent fuel rack storage configuration limitations.

There is no increase in the consequences of the accidental misloading of a spent fuel assembly into the spent fuel racks. The criticality analysis, performed by SCE, demonstrates that the pool Keff will be maintained less than or equal to 0.95 following an accidental misloading by the boron concentration of the pool. The proposed Technical Specification 3.7.17 will ensure that an adequate spent fuel pool boron concentration is maintained.

Significant Change in Spent Fuel Pool Temperature There is no significant increase in the probability of either the loss of normal cooling to the spent fuel pool water or a decrease in pool water temperature from a large emergency makeup when assuming a complete loss of the Boraflex panels and considering the presence of soluble boron in the spent fuel pool water. A high concentration (> 2000 parts per million (ppm)) of soluble boron has always been maintained in the spent fuel pool water. The proposed minimum boron concentration of 2000 ppm in Technical Specification 3.7.17 will ensure that an adequate spent fuel pool concentration is maintained in the spent fuel pools.

A loss of normal cooling to the spent fuel pool water causes an increase in the temperature of the water passing through the stored fuel assemblies. This causes a decrease in water density, and when coupled with the assumption of a complete loss of Boraflex, may result in a positive reactivity addition. However, the additional negative reactivity provided by the boron concentration limit in the proposed Technical Specification 3.7.17 will compensate for the increased reactivity which could result from a loss of spent fuel pool cooling. Because adequate soluble boron will be maintained in the spent fuel pool water to maintain Keff less than or equal to 0.95, the consequences of a loss of normal cooling to the spent fuel pool will not be increased.

A decrease in pool water temperature causes an increase in water density and may result in an increase in reactivity when the Boraflex panels are present in the racks. However, the additional negative reactivity provided by the boron concentration limit in the proposed Technical Specification 3.7.17, determined based on the conservative assumption of a complete loss of the Boraflex, will compensate for the increased reactivity which could result from a decrease in pool water temperature.

Enclosure 2 Licensee Evaluation Page 8 of 12

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

NO.

Criticality accidents in the spent fuel pool are not new or different. They have been analyzed in the Updated Final Safety Analysis Report (UFSAR) and in previous submittals to the Nuclear Regulatory Commission (NRC). Specific accidents considered and evaluated include fuel assembly drop, fuel assembly misloading in the racks, and spent fuel pool water temperature changes.

The possibility for creating a new or different kind of accident is not credible.

Neither Boraflex or soluble boron are accident initiators. The proposed change takes credit for soluble boron in the spent fuel pool while maintaining the necessary margin of safety. Because soluble boron has always been present in the spent fuel pool, a dilution of the spent fuel pool soluble boron has always been a possibility. However this accident was not considered credible. For this proposed amendment, SCE performed a spent fuel pool dilution analysis, which demonstrated that a dilution of the boron concentration in the spent fuel pool water which could increase the rack Keff to greater than 0.95 (constituting a reduction of the required margin to criticality) is not a credible event. The requirement to maintain boron concentration in the spent fuel pool water for reactivity control will have no effect on normal pool operations and maintenance.

There are no changes in equipment design or in plant configuration. This new requirement will not result in the installation of any new equipment or modification of any existing equipment.

Therefore, the proposed change will not result in the possibility of a new or different kind of accident from any accident previously evaluated.

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

NO.

The Technical Specification changes proposed by this License Amendment request and the resulting spent fuel storage operation limits will provide adequate safety margin to ensure that the stored fuel assembly array will always remain subcritical. Those limits are based on a San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 plant specific analysis performed in accordance with a methodology previously approved by the NRC.

Enclosure 2 Licensee Evaluation Page 9 of 12 The proposed change takes partial credit for soluble boron in the spent fuel pool.

SCE's analyses show that spent fuel storage requirements meet the following NRC acceptance criteria for preventing criticality outside the reactor:

(1) The neutron multiplication factor, Kef , including all uncertainties, shall be less than 1.0 when flooded with unborated water, and, (2) The neutron multiplication factor, Keff, including all uncertainties, shall be less than or equal to 0.95 when flooded with borated water.

The criticality analysis utilized credit for soluble boron to ensure Keff will be less than or equal to 0.95 under normal circumstances, and storage configurations have been defined using a 95/95 Keff calculation to ensure that the spent fuel rack will be less than 1.0 with no soluble boron. Soluble boron credit is used to provide safety margin by maintaining Ke, less than or equal to 0.95 including uncertainties, tolerances and accident conditions in the presence of spent fuel pool soluble boron. The loss of a substantial amount of soluble boron from the spent fuel pool water which could lead to Keff exceeding 0.95 has been evaluated and shown to not be credible.

Also, the spent fuel rack Ke, will remain less than 1.0 with the spent fuel pool flooded with unborated water.

Decay heat, radiological effects, and seismic loads are unchanged by the absence of Boraflex.

Therefore, the proposed change does not involve a significant reduction in the plant's margin of safety.

5.2 Applicable Regulatory Requirements/Criteria Code of Federal Regulations, 10 CFR 50, Appendix A Criterion 61 -- Fuel storage and handling and radioactivity control. The fuel storage and handling, radioactive waste, and other systems which may contain radioactivity shall be designed to assure adequate safety under normal and postulated accident conditions. These systems shall be designed (1) with a capability to permit appropriate periodic inspection and testing of components important to safety, (2) with suitable shielding for radiation protection, (3) with appropriate containment, confinement, and filtering systems, (4) with a residual heat removal capability having reliability and testability that reflects the importance to safety of decay heat and other residual heat removal, and (5) to prevent significant reduction in fuel storage coolant inventory under accident conditions.

Criterion 62 -- Prevention of criticality in fuel storage and handling. Criticality in the fuel storage and handling system shall be prevented by physical systems or processes, preferably by use of geometrically safe configurations.

Enclosure 2 Licensee Evaluation Page 10 of 12 Criterion 63 -- Monitoring fuel and waste storage. Appropriate systems shall be provided in fuel storage and radioactive waste systems and associated handling areas (1) to detect conditions that may result in loss of residual heat removal capability and excessive radiation levels and (2) to initiate appropriate safety actions.

The NRC initially reviewed the fuel handling and storage at San Onofre Units 2 and 3 and found it acceptable, as documented in NUREG 0712, Reference 1.

On May 1, 1990, the NRC staff issued the safety evaluation report, Reference 2, prior to spent fuel pool rack replacement. As documented in Reference 2, the staff found that SCE met the requirements of 10 CFR 50, Appendix A, General Design Criterion 61, regarding the capability to permit appropriate periodic inspection and testing of fuel storage components, and General Design Criterion 62, regarding prevention of criticality by the structural integrity of components and of the boron absorber. On September 19, 1996, a letter to SCE from the NRC, Reference 3, documented the completion of a detailed review of spent fuel storage pool safety issues. The results of the staff's review are documented in a report to the Commission. In the report, the staff concluded that existing structures, systems, and components related to the storage of irradiated fuel provide adequate protection of public health and safety. This report addressed adherence to General Design Criteria 61, 62, and 63. By letter dated October 3, 1996, Reference 4, the NRC issued amendments which revised Technical Specification Section 4.3, "Fuel Storage," to allow fuel assemblies having a maximum U-235 enrichment of 4.8 weight percent (w/o) to be stored in the spent fuel racks. The safety evaluation report enclosed with the October 3, 1996, letter stated that General Design Criterion 62 continued to be satisfied.

SCE is anticipating that in the future, the Boraflex panels that line the fuel storage cells will cease to effectively absorb neutrons, and therefore, SCE will not be able to credit Boraflex in maintaining Keff to less than 0.95. The purpose of the proposed technical specifications is to provide fuel storage design (without Boraflex), and fuel storage configuration requirements (based on initial enrichment, burnup, and cooling time), to maintain Ke,, less than 1, and to maintain Keff less than or equal to 0.95 with soluble boron. The anticipated loss of Boraflex and the crediting of soluble boron, already present in the spent fuel pool, does not affect the ability of the fuel storage and handling system to meet Criterion 61 and Criterion 63. Therefore, the previously reviewed findings that General Design Criterion 61 and 63 are met at San Onofre Units 2 and 3 are not affected by this proposed change.

The proposed Fuel Storage Program, Attachment I, meets General Design Criterion 62 by establishing allowable storage configurations that will maintain Keff to less than 1.0. Soluble boron is credited to maintain Keff to less than or equal to 0.95. The proposed Fuel Storage Program is being submitted to the NRC for review and approval. Technical Specification 5.5.2.16, "Fuel Storage Program,"

will be implemented by station procedures which provide a process to maintain the fuel storage in safe configurations.

Enclosure 2 Licensee Evaluation Page 11 of 12 Regulatory Guide Regulatory Guide 1.13 "Spent Fuel Storage Facility Design Basis" describes a method acceptable to the NRC staff for implementing Criterion 61. As stated above, the ability of the fuel storage and handling system to meet Criterion 61 is not affected by this proposed change.

Regulatory Correspondence Nuclear Regulatory Commission, Letter to All Power Reactor Licensees, B. K. Grimes, April 14, 1978, "OT Position for Review and Acceptance of Spent Fuel Storage and Handling Applications," as amended by the NRC letter dated January 18, 1979 USNRC, Office Of Nuclear Reactor Regulation, Reactor Systems Branch, 1998, "Guidance On The Regulatory Requirements For Criticality Analysis Of Fuel Storage At Light-Water Reactor Power Plants" NRC Regulatory Issue Summary 2001-12, May 18, 2001, "Nonconservatism in Pressurized Water Reactor Spent Fuel Storage Pool Reactivity Equivalencing Calculations" The criticality analysis, Attachment K, which supports the proposed Fuel Storage Program, Attachment I, addressed the guidance provided in the above correspondence.

5.3 Administrative Controls Storage of fuel assemblies in the SONGS Units 2 and 3 spent fuel storage racks will be in accordance with the administrative controls described in Technical Specification Section 5.5.2.16, "Fuel Storage Program."

The "Fuel Storage Program (Assuming No Boraflex), San Onofre Nuclear Generating Station, Units 2 and 3," is being submitted as part of this Amendment Application for NRC review and approval. Section 5.5.2.16 will contain the approval date and NRC transmittal letter information. Changes to the Fuel Storage Program will require prior NRC approval.

5.4 Conclusion 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.

Enclosure 2 Licensee Evaluation Page 12 of 12

6.0 ENVIRONMENTAL CONSIDERATION

The proposed Technical Specification amendment has been reviewed against the criteria of 10 CFR 51.22 for environmental considerations. SCE has determined that the proposed amendment does not involve a significant hazards consideration, nor increase the types and amounts of effluents that may be released offsite, nor increase individual or cumulative occupational radiation exposures. Therefore, the proposed amendment meets the criteria given in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Assessment.

7.0 REFERENCES

(1) NUREG-0712 Safety Evaluation Report Related to the Operation of San Onofre Nuclear Generating Station, Units 2 and 3, dated February 1981 (2) Letter from L. E. Kokajko (NRC) to H. B. Ray (SCE) dated May 1, 1990;

Subject:

Issuance of Amendment No.87 to Faciltiy Operating License No.

NPF-10 and Amendment No.77 to Faciltiy Operating License No. NPF-15, San Onofre Nuclear Generating Station, Unit Nos. 2 and 3, (TAC Nos.

68308 and 68309)

(3) Letter from M. B. Fields (NRC) to H. B. Ray (SCE) dated September 19, 1996;

Subject:

Resolution of Spent Fuel Storage Pool Safety Issues:

Issuance of Final Report, San Onofre Nuclear Generating Station, Units. 2 and 3, (TAO No. M88094)

(4) Letter from M. B. Fields (NRC) to H. B. Ray (SCE) dated October 3, 1996, Issuance of Amendment for San Onofre Nuclear Generating Station Unit No. 2 (TAC NO. M94624) and UNIT No. 3 (TAO NO. M94625)

PCN-536 Attachment A (Existing Technical Specification Pages, Unit 2)

Fuel Storage Pool Boron Concentration 3.7.17 3.7 PLANT SYSTEMS 3.7.17 Fuel Storage Pool Boron Concentration LCO 3.7.17 The fuel storage pool boron concentration shall be S1850 ppm.

APPLICABILITY: When fuel assemblies are stored in the fuel storage pool and a fuel storage pool verification has not been performed since the last movement of fuel assemblies in the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel storage pool NOTE----------------------

boron concentration LCO 3.0.3 is not applicable.

not within limit.

A.1 Suspend movement of Immediately fuel assemblies in the fuel storage pool.

AND A.2.1 Initiate action to Immediately restore fuel storage pool boron concentration to within limit.

OR A.2.2 Verify by Immediately administrative means Region II fuel storage pool verification has been performed since the last movement of fuel assemblies in the fuel storage pool.

SAN ONOFRE--UNIT 2 3.7-30 Amendment No. 127

Spent Fuel Assembly Storage 3.7.18 3.7 PLANT SYSTEMS 3.7.18 Spent Fuel Assembly Storage LCO 3.7.18 The combination of initial enrichment and burnup of each SONGS 2 and 3 spent fuel assembly stored in Region II shall be within the acceptable burnup domain of Figure 3.7.18-1 or Figure 3.7.18-2, or the fuel assembly shall be stored in accordance with Licensee Controlled Specification 4.0.100.

The burnup of each SONGS 1 uranium dioxide spent fuel assembly stored in Region II shall be greater than or equal to 18.0 GWD/T for interior locations of 5.5 GWD/T for peripheral locations, or the fuel assembly shall be stored in accordance with Licensee Controlled Specification 4.0.100.

APPLICABILITY: Whenever any fuel assembly is stored in Region II of the fuel storage pool.

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

LCO not met. LCO 3.0.3 is not applicable.

Initiate action to Immediately move the noncomplying fuel assembly from Region II.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.18.1 Verify by administrative means the initial Prior to enrichment and burnup of the fuel assembly storing the is in accordance with LCO 3.7.18. fuel assembly in Region II SAN ONOFRE--UNIT 2 3.7-32 Amendment No. 42-4, 131

Spent Fuel Assembly Storage 3.7.18 4d

-. 4 , , .

I _____ _____ _____________ A 4 4 -..---

S35

- J. .-.--- -.---- 4 S30 ___________ 4 . -.

(9 I. I 1-1

__________ 1 "c-25 - ACCEPTABLE - 4-'---4 4 i

¶ .1.

".20 I 4

4

___________________ 4 -

-I L

& -4 I-. it..,

r10 4.-..-

NOT ACCEPTABLEO x W*

+

"

  • f...

Cfl5

-+ -

i 0 1, 1'. 5 2.0 2.5 3.0 3.5 4.0 4-5 5 Initial U-235 Enrichment (w/o)

MINIMUM BURNUP VS. INITIAL ENRICHMENT FOR UNRESTRICTED PLACEMENT OF SONGS 2 AND 3 FUEL IN REGION II RACKS FIGURE 3.7.18-1 SAN ONOFRE-- -UNIT 2 3.7-33 Amendmen t No. 4-2-, 131

Spent Fuel Assembly Storage 3.7.18

.40 30 - K_

_20 C*10 "

t-- i 4  !-NOT ACCEPT-ABLE*

5.

S0 _ _..

1.5 2.0 2.5 3.0 3.5 4.0 4.5 5.0 Initial U-235 Enrichment (w/o)

MINIMUM BURNUP VS. INITIAL ENRICHMENT FOR PLACEMENT OF SONGS 2 AND 3 FUEL IN REGION II PERIPHERAL POOL LOCATIONS FIGURE 3.7.18-2 SAN ONOF* RE--UNIT 2 3.7-34 Amendment No. +-7£-, 131

Design Features 4.0 4.0 DESIGN FEATURES (continued) 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum U-235 enrichment of 4.8 weight percent;
b. Keff
  • 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR;
c. A nominal 8.85 inch center to center distance between fuel assemblies placed in Region II;
d. A nominal 10.40 inch center to center distance between fuel assemblies placed in Region I;
e. Units 1, 2, and 3 fuel assemblies may be stored in Region I with no restrictions;
f. Units 2 and 3 fuel assemblies with a burnup in the "acceptable range" of Figure 3.7.18-1 are allowed unrestricted storage in Region II;
g. Units 2 and 3 fuel assemblies with a burnup in the "acceptable range" of Figure 3.7.18-2 are allowed unrestricted storage in the peripheral pool locations with 1 or 2 faces toward the spent fuel pool walls of Region II;
h. Fuel assemblies with a burnup in the "unacceptable range" of Figure 3.7.18-1 and Figure 3.7.18-2 will be stored in compliance with the Licensee Controlled Specification 4.0.100; and
i. The burnup of each SONGS 1 uranium dioxide spent fuel assembly stored in Region II shall be greater than or equal to 18.0 GWD/T for interior locations or 5.5 GWD/T for peripheral locations, or the fuel assembly shall be stored in accordance with Licensee Controlled Specification 4.0.100.

(continued)

SAN ONOFRE--UNIT 2 4.0-4 Amendment No. +/-2-T, 131

Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued) 5.5.2.15 Containment Leakage Rate Testing Program (Continued)

The provisions of Surveillance Requirement 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program. However, test frequencies specified in this Program may be extended consistent with the guidance provided in NEI 94-01, "Industry Guideline For Implementing Performance-Based Option Of 10CFR 50, Appendix J," as endorsed by Regulatory Guide 1.163. Specifically, NEI 94-01 has these provisions for test frequencies extension:

1. Consistent with standard scheduling practices for Technical Specifications Required Surveillances, intervals for recommended Type A testing may be extended by up to 15 months. This option should be used only in cases where refueling schedules have been changed to accommodate other factors.
2. Consistent with standard scheduling practices for Technical Specifications Required Surveillances, intervals for the recommended surveillance frequency for Type B and Type C testing may be extended by up to 25 percent of the test interval, not to exceed 15 months.

The provisions of Surveillance Requirement 3.0.3 are applicable to the Containment Leakage Rate Testing Program.

SAN ONOFRE--UNIT 2 5.0-20b Amendment No. 144

PCN-536 Attachment B (Existing Technical Specification Pages, Unit 3)

Fuel Storage Pool Boron Concentration 3.7.17 3.7 PLANT SYSTEMS 3.7.17 Fuel Storage Pool Boron Concentration LCO 3.7.17 The fuel storage pool boron concentration shall be S1850 ppm.

APPLICABILITY: When fuel assemblies are stored in the fuel storage pool and a fuel storage pool verification has not been performed since the last movement of fuel assemblies in the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel storage pool -------------NOTE----------

boron concentration LCO 3.0.3 is not applicable.

not within limit.

A.1 Suspend movement of Immediately fuel assemblies in the fuel storage pool.

AND A.2.1 Initiate action to Immediately restore fuel storage pool boron concentration to within limit.

OR A.2.2 Verify by Immediately administrative means Region II fuel storage pool verification has been performed since the last movement of fuel assemblies in the fuel storage pool.

SAN ONOFRE--UNIT 3 3.7-30 Amendment No. 116

Spent Fuel Assembly Storage 3.7.18 3.7 PLANT SYSTEMS 3.7.18 Spent Fuel Assembly Storage LCO 3.7.18 The combination of initial enrichment and burnup of each SONGS 2 and 3 spent fuel assembly stored in Region II shall be within the acceptable burnup domain of Figure 3.7.18-1 or Figure 3.7.18-2, or the fuel assembly shall be stored in accordance with Licensee Controlled Specification 4.0.100.

The burnup of each SONGS I uranium dioxide spent fuel assembly stored in Region II shall be greater than or equal to 18.0 GWD/T for interior locations of 5.5 GWD/T for peripheral locations, or the fuel assembly shall be stored in accordance with Licensee Controlled Specification 4.0.100.

APPLICABILITY: Whenever any fuel assembly is stored in Region II of the fuel storage pool.

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

LCO not met. LCO 3.0.3 is not applicable.

Initiate action to Immediately move the noncomplying fuel assembly from Region II.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.18.1 Verify by administrative means the initial Prior to enrichment and burnup of the fuel assembly storing the is in accordance with LCO 3.7.18. fuel assembly in Region II SAN ONOFRE--UNIT 3 3.7-32 Amendment No. 4-46, 120

Spent Fuel Assembly Storage 3.7.18 35 Z.Z30;  :,

c-25 - _ _ _ _ _

m lO _ _ _ __ _ __ _ _ _ _ _

~1 0 J 0........ 7 -[NOT ACCEPTABLE 1.5 2.0 2.5 3.0 3.5 4.0 4.5- 5 Initial U-235 Enrichment (w/o)

MINIMUM BURNUP VS. INITIAL ENRICHMENT FOR UNRESTRICTED PLACEMENT OF SONGS 2 AND 3 FUEL IN REGION II RACKS FIGURE 3.7.18-1 SAN ONOFRE--UNIT 3 3.7-33 Amendment No. 14-6, 120

Spent Fuel Assembly Storage 3.7.18 40o S3 5 V ______ _______ _______ ______

  • c...5.._

~2 0 .

W15_

C 10NTC ,, , ! *NOT ACCEPTABLE T in 5  ! / i I i .. L 0oi I i i i ! . ..b -

1.5 2.0 2.5 3.0 3.5 4.0 4.5 5.0 Initial U-235 Enrichment (w/o)

MINIMUM BURNUP VS. INITIAL ENRICHMENT FOR PLACEMENT OF SONGS 2 AND 3 FUEL IN REGION II PERIPHERAL POOL LOCATIONS FIGURE 3.7.18-2 SAN ONOFR E--UNIT 3 3.7-34 Amendment Ni

o. i--, 120

Design Features 4.0 4.0 DESIGN FEATURES (continued) 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum U-235 enrichment of 4.8 weight percent;
b. Keff
  • 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR;
c. A nominal 8.85 inch center to center distance between fuel assemblies placed in Region II;
d. A nominal 10.40 inch center to center distance between fuel assemblies placed in Region I;
e. Units 1, 2, and 3 fuel assemblies may be stored in Region I with no restrictions;
f. Units 2 and 3 fuel assemblies with a burnup in the "acceptable range" of Figure 3.7.18-1 are allowed unrestricted storage in Region II;
g. Units 2 and 3 fuel assemblies with a burnup in the "acceptable range" of Figure 3.7.18-2 are allowed unrestricted storage in the peripheral pool locations with I or 2 faces toward the spent fuel pool walls of Region II;
h. Fuel assemblies with a burnup in the "unacceptable range" of Figure 3.7.18-1 and Figure 3.7.18-2 will be stored in compliance with the Licensee Controlled Specification 4.0.100; and
i. The burnup of each SONGS 1 uranium dioxide spent fuel assembly stored in Region II shall be greater than or equal to 18.0 GWD/T for interior locations or 5.5 GWD/T for peripheral locations, or the fuel assembly shall be stored in accordance with Licensee Controlled Specification 4.0.100.

(continued)

SAN ONOFRE--UNIT 3 4.0-4 Amendment No. +-1-6, 120

Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued) 5.5.2.15 Containment Leakage Rate Testing Program (Continued)

The provisions of Surveillance Requirement 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program. However, test frequencies specified in this Program may be extended consistent with the guidance provided in NEI 94-01, "Industry Guideline For Implementing Performance-Based Option Of 10CFR 50, Appendix J," as endorsed by Regulatory Guide 1.163. Specifically, NEI 94-01 has these provisions for test frequencies extension:

1. Consistent with standard scheduling practices for Technical Specifications Required Surveillances, intervals for recommended Type A testing may be extended by up to 15 months. This option should be used only in cases where refueling schedules have been changed to accommodate other factors.
2. Consistent with standard scheduling practices for Technical Specifications Required Surveillances, intervals for the recommended surveillance frequency for Type B and Type C testing may be extended by up to 25 percent of the test interval, not to exceed 15 months.

The provisions of Surveillance Requirement 3.0.3 are applicable to the Containment Leakage Rate Testing Program.

SAN ONOFRE--UNIT 3 5.0-20b Amendment No. 135

PCN-536 Attachment C (Proposed Technical Specification Pages)

(Redline and Strikeout, Unit 2)

Fuel Storage Pool Boron Concentration 3.7.17 3.7 PLANT SYSTEMS 3.7.17 Fuel Storage Pool Boron Concentration LCO 3.7.17 The fuel storage pool boron concentration shall be

> 8-5G2000 ppm.

APPLICABILITY: Whenever any fuel assembly-er *-eeis stored in the fuel storage pool. and a fuel storage pool verifiation has rl hAR. Aaýrf AW iiQd t1-a.. ' I*6

- IR - *i I IAA-M.+Af IF '

a 3 5 efflui ies in the x, I Q,LWar_ýJý - - - [JUW - - I.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel storage pool NOTE----------------------

boron concentration LCO 3.0.3 is not applicable.

not within limit.

A.I Suspend movement of Immediately fuel assemblies in the fuel storage pool.

AND A.2--+ Initiate action to Immediately restore fuel storage pool boron concentration to within limit.

OR A.2.2 Verify by fimmedi at-'

'~IIII I I ,. , U %, I V I* II*;QI I l Region II fuel storage-pot+

verification has bee-n p.Iformed sinle the I J-, IIIILV I mII I. VI I assemfblies in the fuel storage pool.

SAN ONOFRE--UNIT 2 3.7-30 Amendment No. 2;

Spent Fuel Assembly Storage 3.7.18 3.7 PLANT SYSTEMS 3.7.18 Spent Fuel Assembly Storage LCO 3.7.18 -rL-Ii

-LZ-ýZ COMO! iid;,!UriL

_ ,,C -'_-'I.

U 2 _"I U .1Id efrit.icrerit and Durnup i*

or ea.n I

SONGS 2 and 3 spent fuel assembly stored- in Region II shall be within the aeccptable burnup, d,,main of Figure 3.7.18-1 or Figure 3.7.18 2, or the fuel assembly shall be stored in accordance with Lienmsec Controlled Specification 4.0.100.

The burnup of 4* each 4 4.LI SONGS A-J 1 uranium dioxide spent fuecl assembly stored in Region II shall be greater than or equal peripheral locations, or the fuel assembly shall be stared "1

III {1I.iui

1. u ni'L- U i i . b.

UHU-C IV T 1, L- L I,,.. UU,,n , oi i.U i iiLeirIi "4. 0. J.9.

The storage of SONGS Units 1, 2, and 3 fuel assemblies in the spent fuel storage racks shall be in accordance with Technical Specification 5.5.2.16, "Fuel Storage Program."

APPLICABILITY: Whenever any fuel assembly is stored in Reg-i-on af--the fuel storage pool.

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

LCO not met. LCO 3.0.3 is not applicable.

Initiate action to Immediately move bring the noncomplying fuel assembly freom Region !into compliance.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.18.1 Verify by administrative means the initial Prior to enrichment, eftnd-burnup, and cooling time of storing fuel assembly the the fuel assembly -s-are in accordance with in Region I or LCO 3.7.18. II SAN ONOFRE--UNIT 2 3.7-32 Amendment No. 2-7, 1-3

Spent Fuel Assembly Storage 3.7.18 FIGURE DELETED FIGURE 3.7.18 1 SAN ONOFRE--UNIT 2 3.7-33 Amendment No. +/-27, 1'3

Spent Fuel Assembly Storage 3.7.18 FIGURE DELETED FIGURE 3.7.18 2 SAN ONOFRE--UNIT 2 3.7-34 Amendment No. +/-27, 131

Design Features 4.0 4.0 DESIGN FEATURES (continued) 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum nominal U-235 enrichment of 4.8 weight percent;
b. Keff s< 0--9-51.0 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR;
c. Keff _<0.95 if fully flooded with water borated to 1700 ppm, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR; e-.d. A nominal 8.85 inch center to center distance between fuel assemblies placed in Region II; ti.-e. A nominal 10.40 inch center to center distance between fuel assemblies placed in Region I; and e-rf. Units 1, 2, and 3 fuel assemblies may be stored in Re,*ion I with no restrictions.shall be stored in accordance with Technical Specification 5.5.2.16, "Fuel Storage Program."
f. Units 2 and 3 fuel assemblies with a burnup in the "1acceptable range" of Figure '3.7.18 1 are allowed unrestricted storage in Region- II; Units 2 and 3 fuel assemnblies- with a burnup in the "Iacceptable range" of Figure 3.7.18 2 are allowed hr unrestricted storage in the peripheral pool locations with 1 or 2 faces toward the spent fuel pool walls of Region . .,

Fuel assemiblies with a burnup in the "unacceptable range" of Figure 3.7.18 1 and Figure 3.7.18 2 will be stored in compliance with the Licensee Controlled Specification 4.0.100; and The burnup of each SONGS 1 uraniumn dioxide spent fuel assembly stored in ll Region shall be greater than or equall toV 18.0 GWD94/4 for interior locationsý

  • 5.5 CWD/

I f oIr peri p heral locations, or the fuel assembly shall be stor-ed in.acodance with Liensee Contro6led Specification 4.0.100.

(conti nued)

SAN ONOFRE--UNIT 2 4.0-4 Amendment No. -127,r 3

Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued) 5.5.2.15 Containment Leakage Rate Testing Program (Continued)

The provisions of Surveillance Requirement 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program. However, test frequencies specified in this Program may be extended consistent with the guidance provided in NEI 94-01, "Industry Guideline For Implementing Performance-Based Option Of IOCFR 50, Appendix J," as endorsed by Regulatory Guide 1.163. Specifically, NEI 94-01 has these provisions for test frequencies extension:

1. Consistent with standard scheduling practices for Technical Specifications Required Surveillances, intervals for recommended Type A testing may be extended by up to 15 months. This option should be used only in cases where refueling schedules have been changed to accommodate other factors.
2. Consistent with standard scheduling practices for Technical Specifications Required Surveillances, intervals for the recommended surveillance frequency for Type B and Type C testing may be extended by up to 25 percent of the test interval, not to exceed 15 months.

The provisions of Surveillance Requirement 3.0.3 are applicable to the Containment Leakage Rate Testing Program.

5.5.2.16 Fuel Storage Program

a. A program shall be established to provide safe storage of fuel assemblies in the SONGS Units 2 and 3 spent fuel storage racks assuming no Boraflex, and taking credit for soluble boron in the spent fuel pool water.

The program, in conjunction with Technical Specifications 3.7.17, "Fuel Storage Boron Concentration," 3.7.18, "Spent Fuel Assembly Storage," and 4.3, "Fuel Storage," shall assure that:

(1) Under normal conditions, the 95/95 neutron multiplication factor (Keff), including all uncertainties, shall be less than 1.0 when flooded with unborated water.

(2) Under normal and accident conditions, the 95/95 neutron multiplication factor (Keff), including all uncertainties, shall be less than or equal to 0.95 when flooded with borated water.

(continued)

SAN ONOFRE--UNIT 2 5.0-20b Amendment No. -4

Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued) 5.5.2.16 Fuel Storage Program (continued)

b. The storage requirements, based on initial enrichment, burnup data, and cooling time (which determines plutonium decay) shall be contained in a program document previously approved by the NRC. SONGS Units 2 and 3 fuel storage pool shall be maintained in accordance with: "Fuel Storage Program (Assuming No Boraflex) San Onofre Nuclear Generating Station Units 2 and 3, February 2002" approved by the NRC Safety Evaluation Report transmitted in a letter from (NRC) to - (SCE), dated  ;

Subject:

SAN ONOFRE--UNIT 2 5.0-20c Amendment No.

Attachment D (Proposed Technical Specification Pages)

(Redline and Strikeout, Unit 3)

Fuel Storage Pool Boron Concentration 3.7.17 3.7 PLANT SYSTEMS 3.7.17 Fuel Storage Pool Boron Concentration LCO 3.7.17 The fuel storage pool boron concentration shall be

>--85G2000 ppm.

APPLICABILITY: Whenever any fuel assembly+e-s- areis stored in the fuel storageMA+

6,,=~ pool. and a fuel ,ae* , storageL*, laQ pool FRAQFl ver*ifatian v R rlf f* ha&

IJL. &J'.L.II jJI lul IIIU 3 iII.A LiI I

3. F I I . .. . . I. . . . ... . . . ......

- r" ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel storage pool ------------ NOTE---------

boron concentration LCO 3.0.3 is not applicable.

not within limit.

A.1 Suspend movement of Immediately fuel assemblies in the fuel storage pool.

AND A.2 Initiate action to Immediately restore fuel storage pool boron concentration to within limit.

OR A.2.2 Verify by imedi-ae-y administrative means Region II fuel verification has ben prfrmed sinCe the last movem..ent of fuel assemblies in the fuel storage pool SAN ONOFRE--UNIT 3 3.7-30 Amendment No.*4-

Spent Fuel Assembly Storage 3.7.18 3.7 PLANT SYSTEMS 3.7.18 Spent Fuel Assembly Storage LCO 3.7.18 !me eambination at initial enriehment and burnup of eaeh

.I, .I I . 0 L3 III I J- UI U II I U II aL. a-I-U-II r 4 ',.3 -7 10 0 e) - -- L - C.. , -I ..- -1 -LI.. -- L-1 1 L -- - - ....-- I I I Ul . r.,,L--., UI C I LI I U CI (*.IIt t lJ 0,U 1 I l I I U I a,,ardance with Lieensee Cntralled Spe*ilfiatian 4.0.100.

The burnup of cach SONGS 1 uranium dioxide spent fuel assembly stored in Region shall be greater II than or equal peripheral laeatians, or the fuel assembly sHallbesad in accardance with Licensee Cantrllcd Speificatian The storage of SONGS Units 1, 2, and 3 fuel assemblies in the spent fuel storage racks shall be in accordance with Technical Specification 5.5.2.16, "Fuel Storage Program."

APPLICABILITY: Whenever any fuel assembly is stored in Region .5 , f-the fuel storage pool.

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

LCO not met. LCO 3.0.3 is not applicable.

Initiate action to Immediately movebring the noncomplying fuel assembly 'Fiom Reia into compliance.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.18.1 Verify by administrative means the initial Prior to enrichment, aii-d-burnup, and cooling time of storing the fuel assembly the fuel assembly i-sare in accordance with in Region I or LCO 3.7.18. II SAN ONOFRE--UNIT 3 3.7-32 Amendment No. 116, 120

Spent Fuel Assembly Storage 3.7.18 FIGURE DELETED MINIMUM B VI1. TITTAF IU IT* EICHMENT FOR UNRESTRICTED fPLACEMEN I"*T OF SONGSl*C 2' ANDi~ 3l FIUEI TNE il-Tl~ GIO RTi'ACKS/(

FIGURE* 3.7.18-1 SAN ONOFRE--UNIT 3 3.7-33 Amendment No. 116,I-2

Spent Fuel Assembly Storage 3.7.18 FIGURE DELETED MINIMU ,, , ,UN VS. ,T" IAL[ ENRI3CHMENT FOR*,, MENT Vl ~~ fI# ~ ~ ~

.L.Ji FG R . 3.~l*J 7J.%

1 8 2# 1~#% V- ~.f% .V*.

SAN ONOFRE--UNIT 3 3.7-34 Amendment No. 116, 120

Design Features 4.0 4.0 DESIGN FEATURES (continued) 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum nominal U-235 enrichment of 4.8 weight percent;
b. Keff 7< &-.9-51.0 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR; C. Keff
  • 0.95 if fully flooded with water borated to 1700 ppm, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR; e--d. A nominal 8.85 inch center to center distance between fuel assemblies placed in Region II; d--.e. A nominal 10.40 inch center to center distance between fuel assemblies placed in Region I; and e--f. Units 1, 2, and 3 fuel assemblies may be stored in Reian I with ne restri.tions.shall be stored in accordance with Technical Specification 5.5.2.16, "Fuel Storage Program."
f. Units 2 and 3 fuel assemblies with a burnup in the "1aeptablerange" of Figure 3.71.18 1 are allowed
nrP%*triP*A Q4- P - j. r * -4P ni TT-Units 2 and 3lfuel assembI es with'. U, in a uL- th

"!acfepFtable range" of Figure 3.7.18 2 are allowed unr st-,uricted storage in the peripheral pool locations with 1 or 2 faces toward the spent fuel pool walls of Region II; Fuel assemblies with a burnup in the "unacceptable range" of Figure 3.7.18 1 and Figure 3.7.18 2 will be stored in compliance with the Licensee Controlled Specification 4.0.100, and The burnup of each SONGS 1 uranium dioxide spntl fuel assembly stored in Region- 1 shall be greater than or equal to 18.0 4 W.-T for interior locationsI or 5.5 GWDII T for peripheral locations, or the fuel assembly shall be stored in accordance with Liensee Controlled Specification 4.0.100.

(conti nued)

SAN ONOFRE--UNIT 3 4.0-4 Amendment No. 1-6, 120

Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued) 5.5.2.15 Containment Leakage Rate Testing Program (Continued)

The provisions of Surveillance Requirement 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program. However, test frequencies specified in this Program may be extended consistent with the guidance provided in NEI 94-01, "Industry Guideline For Implementing Performance-Based Option Of 10CFR 50, Appendix J," as endorsed by Regulatory Guide 1.163. Specifically, NEI 94-01 has these provisions for test frequencies extension:

1. Consistent with standard scheduling practices for Technical Specifications Required Surveillances, intervals for recommended Type A testing may be extended by up to 15 months. This option should be used only in cases where refueling schedules have been changed to accommodate other factors.
2. Consistent with standard scheduling practices for Technical Specifications Required Surveillances, intervals for the recommended surveillance frequency for Type B and Type C testing may be extended by up to 25 percent of the test interval, not to exceed 15 months.

The provisions of Surveillance Requirement 3.0.3 are applicable to the Containment Leakage Rate Testing Program.

5.5.2.16 Fuel Storage Program

a. A program shall be established to provide safe storage of fuel assemblies in the SONGS Units 2 and 3 spent fuel storage racks assuming no Boraflex, and taking credit for soluble boron in the spent fuel pool water.

The program, in conjunction with Technical Specifications 3.7.17, "Fuel Storage Boron Concentration," 3.7.18, "Spent Fuel Assembly Storage," and 4.3, "Fuel Storage," shall assure that:

(1) Under normal conditions, the 95/95 neutron multiplication factor (Keff), including all uncertainties, shall be less than 1.0 when flooded with unborated water.

(2) Under normal and accident conditions, the 95/95 neutron multiplication factor (Keff), including all uncertainties, shall be less than or equal to 0.95 when flooded with borated water.

(continued)

SAN ONOFRE--UNIT 3 5.0-20b Amendment No. +-

Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued) 5.5.2.16 Fuel Storage Program (continued)

b. The storage requirements, based on initial enrichment, burnup data, and cooling time (which determines plutonium decay) shall be contained in a program document previously approved by the NRC. SONGS Units 2 and 3 fuel storage pool shall be maintained in accordance with: "Fuel Storage Program (Assuming No Boraflex) San Onofre Nuclear Generating Station Units 2 and 3, February 2002" approved by the NRC Safety Evaluation Report transmitted in a letter from _

(NRC) to - (SCE), dated  ;

Subject:

SAN ONOFRE--UNIT 3 5.0-20c Amendment No.

Attachment E (Proposed Technical Specification Pages, Unit 2)

Fuel Storage Pool Boron Concentration 3.7.17 3.7 PLANT SYSTEMS 3.7.17 Fuel Storage Pool Boron Concentration LCO 3.7.17 The fuel storage pool boron concentration shall be S2000 ppm.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel storage pool ------------ NOTE----------

boron concentration LCO 3.0.3 is not applicable.

not within limit.

A.1 Suspend movement of Immediately fuel assemblies in the fuel storage pool.

AND A.2 Initiate action to Immediately restore fuel storage pool boron concentration to within limit.

SAN ONOFRE--UNIT 2 3.7-30 Amendment No.

Spent Fuel Assembly Storage 3.7.18 3.7 PLANT SYSTEMS 3.7.18 Spent Fuel Assembly Storage LCO 3.7.18 The storage of SONGS Units 1, 2, and 3 fuel assemblies in the spent fuel storage racks shall be in accordance with Technical Specification 5.5.2.16, "Fuel Storage Program."

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

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

LCO not met. LCO 3.0.3 is not applicable.

Initiate action to Immediately bring the noncomplying fuel assembly into compliance.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.18.1 Verify by administrative means the initial Prior to enrichment, burnup, and cooling time of the storing the fuel assembly are in accordance with LCO fuel assembly 3.7.18. in Region I or II SAN ONOFRE--UNIT 2 3.7-32 Amendment No.

Spent Fuel Assembly Storage 3.7.18 FIGURE DELETED SAN ONOFRE--UNIT 2 3.7-33 Amendment No.

Spent Fuel Assembly Storage 3.7.18 FIGURE DELETED SAN ONOFRE--UNIT 2 3.7-34 Amendment No.

Design Features 4.0 4.0 DESIGN FEATURES (continued) 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum nominal U-235 enrichment of 4.8 weight percent;
b. Kff < 1.0 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR;
c. Keff
  • 0.95 if fully flooded with water borated to 1700 ppm, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR;
d. A nominal 8.85 inch center to center distance between fuel assemblies placed in Region II;
e. A nominal 10.40 inch center to center distance between fuel assemblies placed in Region I; and
f. Units 1, 2, and 3 fuel assemblies shall be stored in accordance with Technical Specification 5.5.2.16, "Fuel Storage Program."

(continued)

SAN ONOFRE--UNIT 2 4.0-4 Amendment No.

Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued) 5.5.2.15 Containment Leakage Rate Testing Program (Continued)

The provisions of Surveillance Requirement 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program. However, test frequencies specified in this Program may be extended consistent with the guidance provided in NEI 94-01, "Industry Guideline For Implementing Performance-Based Option Of 10CFR 50, Appendix J," as endorsed by Regulatory Guide 1.163. Specifically, NEI 94-01 has these provisions for test frequencies extension:

1. Consistent with standard scheduling practices for Technical Specifications Required Surveillances, intervals for recommended Type A testing may be extended by up to 15 months. This option should be used only in cases where refueling schedules have been changed to accommodate other factors.
2. Consistent with standard scheduling practices for Technical Specifications Required Surveillances, intervals for the recommended surveillance frequency for Type B and Type C testing may be extended by up to 25 percent of the test interval, not to exceed 15 months.

The provisions of Surveillance Requirement 3.0.3 are applicable to the Containment Leakage Rate Testing Program.

5.5.2.16 Fuel Storage Program

a. A program shall be established to provide safe storage of fuel assemblies in the SONGS Units 2 and 3 spent fuel storage racks assuming no Boraflex, and taking credit for soluble boron in the spent fuel pool water.

The program, in conjunction with Technical Specifications 3.7.17, "Fuel Storage Boron Concentration," 3.7.18, "Spent Fuel Assembly Storage," and 4.3, "Fuel Storage," shall assure that:

(1) Under normal conditions, the 95/95 neutron multiplication factor (Kff), including all uncertainties, shall be less than 1.0 when flooded with unborated water.

(2) Under normal and accident conditions, the 95/95 neutron multiplication factor (Keff), including all uncertainties, shall be less than or equal to 0.95 when flooded with borated water.

(continued)

SAN ONOFRE--UNIT 2 5.0-20b Amendment No.

Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued) 5.5.2.16 Fuel Storage Program (continued)

b. The storage requirements, based on initial enrichment, burnup data, and cooling time (which determines plutonium decay) shall be contained in a program document previously approved by the NRC. SONGS Units 2 and 3 fuel storage pool shall be maintained in accordance with: "Fuel Storage Program (Assuming No Boraflex) San Onofre Nuclear Generating Station Units 2 and 3, February 2002" approved by the NRC Safety Evaluation Report transmitted in a letter from (NRC) to _ (SCE), dated  ;

Subject:

SAN ONOFRE--UNIT 2 5.0-20c Amendment No.

PCN-536 Attachment F (Proposed Technical Specification Pages, Unit 3)

Fuel Storage Pool Boron Concentration 3.7.17 3.7 PLANT SYSTEMS 3.7.17 Fuel Storage Pool Boron Concentration LCO 3.7.17 The fuel storage pool boron concentration shall be S2000 ppm.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel storage pool ------------ NOTE---------

boron concentration LCO 3.0.3 is not applicable.

not within limit. -- - - - - - - - - --..

A.1 Suspend movement of Immediately fuel assemblies in the fuel storage pool.

AND A.2 Initiate action to Immediately restore fuel storage pool boron concentration to within limit.

SAN ONOFRE--UNIT 3 3.7-30 Amendment No.

Spent Fuel Assembly Storage 3.7.18 3.7 PLANT SYSTEMS 3.7.18 Spent Fuel Assembly Storage LCO 3.7.18 The storage of SONGS Units 1, 2, and 3 fuel assemblies in the spent fuel storage racks shall be in accordance with Technical Specification 5.5.2.16, "Fuel Storage Program."

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

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

LCO not met. LCO 3.0.3 is not applicable.

Initiate action to Immediately bring the noncomplying fuel assembly into compliance.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.18.1 Verify by administrative means the initial Prior to enrichment, burnup, and cooling time of the storing the fuel assembly are in accordance with LCO fuel assembly 3.7.18. in Region I or II SAN ONOFRE--UNIT 3 3.7-32 Amendment No.

Spent Fuel Assembly Storage 3.7.18 FIGURE DELETED SAN ONOFRE--UNIT 3 3.7-33 Amendment No.

Spent Fuel Assembly Storage 3.7.18 FIGURE DELETED SAN ONOFRE--UNIT 3 3.7-34 Amendment No.

Design Features 4.0 4.0 DESIGN FEATURES (continued) 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum nominal U-235 enrichment of 4.8 weight percent;
b. Keff < 1.0 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR;
c. Keff < 0.95 if fully flooded with water borated to 1700 ppm, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR;
d. A nominal 8.85 inch center to center distance between fuel assemblies placed in Region II;
e. A nominal 10.40 inch center to center distance between fuel assemblies placed in Region I; and
f. Units 1, 2, and 3 fuel assemblies shall be stored in accordance with Technical Specification 5.5.2.16, "Fuel Storage Program."

(continued)

SAN ONOFRE--UNIT 3 4.0-4 Amendment No.

Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued) 5.5.2.15 Containment Leakage Rate Testing Program (Continued)

The provisions of Surveillance Requirement 3.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program. However, test frequencies specified in this Program may be extended consistent with the guidance provided in NEI 94-01, "Industry Guideline For Implementing Performance-Based Option Of IOCFR 50, Appendix J," as endorsed by Regulatory Guide 1.163. Specifically, NEI 94-01 has these provisions for test frequencies extension:

1. Consistent with standard scheduling practices for Technical Specifications Required Surveillances, intervals for recommended Type A testing may be extended by up to 15 months. This option should be used only in cases where refueling schedules have been changed to accommodate other factors.
2. Consistent with standard scheduling practices for Technical Specifications Required Surveillances, intervals for the recommended surveillance frequency for Type B and Type C testing may be extended by up to 25 percent of the test interval, not to exceed 15 months.

The provisions of Surveillance Requirement 3.0.3 are applicable to the Containment Leakage Rate Testing Program.

5.5.2.16 Fuel Storage Program

a. A program shall be established to provide safe storage of fuel assemblies in the SONGS Units 2 and 3 spent fuel storage racks assuming no Boraflex, and taking credit for soluble boron in the spent fuel pool water.

The program, in conjunction with Technical Specifications 3.7.17, "Fuel Storage Boron Concentration," 3.7.18, "Spent Fuel Assembly Storage," and 4.3, "Fuel Storage," shall assure that:

(1) Under normal conditions, the 95/95 neutron multiplication factor (K ), including all uncertainties, shall be less than 1.0 when flooded with unborated water.

(2) Under normal and accident conditions, the 95/95 neutron multiplication factor (Kerr), including all uncertainties, shall be less than or equal to 0.95 when flooded with borated water.

(continued)

SAN ONOFRE--UNIT 3 5.0-20b Amendment No.

Procedures, Programs, and Manuals 5.5 5.5 Procedures, Programs, and Manuals (continued) 5.5.2.16 Fuel Storage Program (continued)

b. The storage requirements, based on initial enrichment, burnup data, and cooling time (which determines plutonium decay) shall be contained in a program document previously approved by the NRC. SONGS Units 2 and 3 fuel storage pool shall be maintained in accordance with: "Fuel Storage Program (Assuming No Boraflex) San Onofre Nuclear Generating Station Units 2 and 3, February 2002" approved by the NRC Safety Evaluation Report transmitted in a letter from (NRC) to - (SCE), dated  ;

Subject:

SAN ONOFRE--UNIT 3 5.0-20c Amendment No.

PCN-536 Attachment G (Proposed Bases Pages (For Information Only) Unit 2)

Fuel Storage Pool Boron Concentration B 3.7.17 B 3.7 PLANT SYSTEMS B 3.7.17 Fuel Storage Pool Boron Concentration BASES BACKGROUND As described in LCO 3.7.18, "Spent Fuel Assembly Storage,"

fuel assemblies are stored in the spent fuel racks in accordance with criteria based on initial enrichment, *-4 discharge burnup, and cooling time (plutonium decay).

Although the water in the spent fuel pool is normally borated to Ž 4-8% 2000 ppm, the criteria that limit the storage of a fuel assembly to specific rack locations is conservatively developed without taking credit for boron-while maintaining Keff < 1.0. Credit for boron is taken to maintain Keff

  • 0.95.

APPLICABLE A fuel assembly could be inadvertently loaded into a spent SAFETY ANALYSES fuel rack location not allowed by LCO 3.7.18 (e.g., an unirradiated fuel assembly or an insufficiently depleted fuel assembly). Thi .... ...

en is_an ly e assmin . the.*

extreme ease of completely leading the fuel pool racks with unirradiated assemblies of maximum erihment. Another type of postulated accident is associated with a fuel assembly that is dropped onto the fully loaded fuel pool storage rack. Either inlident could have a positive reactivity effet, decreasing* the margin to criticality. However, the negative reactivity effect of the soluble boron compensates for the increased reactivity caused by either one the twe postulated accident scenariosr.

Under normal, non-accident conditions, the soluble boron needed to maintain Keff less than or equal to 0.95, including uncertainties, is 970 ppm. Under accident conditions, the soluble boron needed to maintain Keff less than or equal to 0.95, including uncertainties, is 1700 ppm. A SFP boron dilution analysis shows that dilution from 2000 ppm to 1700 is not credible. Therefore, the minimum required soluble boron concentration is 2000 ppm.

The concentration of dissolved boron in the fuel pool satisfies Criterion 2 of the NRC Policy Statement.

(continued)

SAN ONOFRE--UNIT 2 B 3.7-71 Amendment No. 127

Fuel Storage Pool Boron Concentration B 3.7.17 BASES (continued)

LCO The specified concentration of dissolved boron in the fuel pool preserves the assumptions used in the analyses of-the potential accident scenarios described above. This concentration of dissolved boron is the minimum required concentration for fuel assembly storage and movement within the fuel pool.

APPLICABILITY This LCO applies whenever fuel assemblies are stored in the spent fuel pool. until a . .mpletespent fuel patl verification has beer, performed fallowing the last movement of fuel assemblies in the spent fuel pool. This LCO does not apply following the verification sinee the verification would confirm that there are no misloaded fuel assemblies.

With no further fuel assembly movements in prges, there is mo potential for a misloaded fuel assembly or a dropped ACTIONS A.I. A.2, and A.3 The Required Actions are modified by a Note indicating that LCO 3.0.3 does not apply.

When the concentration of boron in the spent fuel pool is less than required, immediate action must be taken to preclude an accident from happening or to mitigate the consequences of an accident in progress. This is most efficiently achieved by immediately suspending the movement of fuel assemblies. This does not preclude the movement of fuel assemblies to a safe position. In addition, action must be immediately initiated to restore boron concentration to within limit. Alternately, an immediate verification, by administrative means, of the fuel storage pool fuel locations, to ensure proper locations of the fuel since the last movement of fuel assemblies in the fuel storage pool, can be performed.

If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operation.

Therefore, inability to suspend movement of fuel assemblies is not sufficient reason to require a reactor shutdown.

(contionued)

SAN ONOFRE--UNIT 2 B 3.7-72 Amendment No. 127

Fuel Storage Pool Boron Concentration B 3.7.17 BASES (continued)

SURVEILLANCE SR 3.7.17.1 REQUIREMENTS This SR verifies that the concentration of boron in the spent fuel pool is within the required limit. As long as this SR is met, the analyzed incidents are fully addressed.

The 7 day Frequency is appropriate because no major replenishment of pool water is expected to take place over a short period of time.

REFERENCES 1. UFSAR, Section 9.1.

SAN ONOFRE--UNIT 2 B 3.7-73 Amendment No. 127

Spent Fuel Assembly Storage B 3.7.18 B 3.7 PLANT SYSTEMS B 3.7.18 Spent Fuel Assembly Storage BASES BACKGROUND The spent fuel storage facility is designed to store either new (nonirradiated) nuclear fuel assemblies, or burned (irradiated) fuel assemblies in a vertical configuration underwater. The storage pool is sized to store 1542 fuel assemblies. Two types/sizes of spent fuel storage racks are used (Region I and Region II). The two Region I racks each contain 156 storage locations each spaced 10.40 inches on center in a 12x13 array. Four Region II storage racks each contain 210 storage locations in a 14x15 array. The remaining two Region II racks each contain 195 locations in a 13x15 array. All Region Ii locations are spaced 8.85 inches on center. This spacing a-d ,flu trap" construltion, wherby* th fluelassemblies ar, inserted iIto eutran absorbing stin.iless steel cans, is sufficient to Tomaintain K'ff - 0.05 for spent fuel of oiinal up to 4.8 w/o, (1) soluble boron is credited, and (2) the following storage patterns and guide tube inserts are used as needed:

(I) unrestricted storage, minimum discharge burnup and cooling time requirements vs. initial enrichment, (2) SFP Peripheral storage, minimum discharge burnup and cooling time requirements vs initial enrichment, (3) 2x2 storage patterns, minimum discharge burnup and cooling time requirements vs initial enrichment, (4) 3x3 storage patterns, minimum discharge burnup and cooling time requirements vs initial enrichment, (conti nued)

SAN ONOFRE--UNIT 2 B 3.7-74 Amendment No. 127 Jd 29,--1994

Spent Fuel Assembly Storage B 3.7.18 BASES (continued)

BACKGROUND (5) credit for inserted Control Element Assemblies (continued) (CEAs),

(6) credit for erbia in fresh assemblies, (7) credit for cooling time (Pu-241 decay), and, (8) credit for borated stainless steel and borated aluminum guide tube inserts.

When soluble boron is credited, the following acceptance criteria apply:

(1) Under normal conditions, the 95/95 neutron multiplication factor (Keff), including all uncertainties, shall be less than 1.0 when flooded with unborated water, and, (2) Under normal and accident conditions, the 95/95 neutron multiplication factor (Keff), including all uncertainties, shall be less than or equal to 0.95 when flooded with borated water.

APPLICABLE The spent fuel storage facility is designed for SAFETY ANALYSES noncriticality by use of adequate spacing, d- ,,flx

.t.ra.-,

mstruetiam whereby the fuel asseffblies are iserted into neutron absorbing stainless steel cans-.-, and storage of fuel assemblies in accordance with the administrative controls in Technical Specification 5.5.2.16, "Fuel Storage Program".

The spent fuel assembly storage satisfies Criterion 2 of the NRC Policy Statement.

LCO The restrictions on the placement of fuel assemblies within the spent fuel pool, according to Figure 3.7.18 1 and Figure 3.7.18-2 Technical Specification 5.5.2.16, in the accompanying LCO, ensures that the Keff of the spent fuel pool will always remain < 0--9-5 1.00 under normal, non accident conditions assuming the pool to be flooded with unborated water. The Keff of the spent fuel pool will always remain < 0.95 under normal, non-accident conditions assuming the pool to be flooded with (continued)

SAN ONOFRE--UNIT 2 B 3.7-75 Amendment No. 127 "ly-29, 1994

Spent Fuel Assembly Storage B 3.7.18 BASES (continued)

LCO borated water with a minimum soluble boron concentration of (continued) 970 ppm. The Kef of the spent fuel pool will always remain

< 0.95 under accident conditions assuming the pool to be flooded with borated water with a minimum soluble boron concentration of 1700 ppm. The restrictions are consistent with the criticality safety analysis performed for the spent fuel pool. aeording to LCO Figure 3.7.18 1 and Figu"re 3.7.18 2, in the accme yn LCO. Fuel assemblies not meeting the riteria f Figure 3.7.18 1 and Figure 3.7.18 2 shall be stared in acccrdanee with Speeifieation 4.3.1.1.

APPLICABILITY This LCO aDolies whenever any fuel assembly is stored in Regions I and II of the spent fuel 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 Regions I and II of the spent fuel pool is not in accordance with Fieure 3.7.18-1 amd Figure 3.7.18 2 Technical Specification 5.5.2.16, immediate action must be taken to make the necessary fuel assembly movement(s) to bring the configuration into comDliance with Ficure 3.7.18 1 and Figure 3.7.18 2 Technical Specification 5.5.2.16.

If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operation.

Therefore, in either case, inability to move fuel assemblies is not sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.7.18.1 REQUIREMENTS This SR verifies by administrative means that the initia+

enrichment and burnup.of the fuel assembly is stored in accordance with Fiqure 3.7.1° 1 and Fioure 3.7.18 2 Technical Specification 5.5.2.16, "Fuel Storage Program" in the accompanying LCO. For fuel assemblies i-n-the uncetbt aceo Ficiure 3.7.18 1 and Ficjure 3.7.18 2 not stored in accordance with Technical Specification 5.5.2.16, performance of this SR will ensure compliance with

&eifiatI, 43.1.1 Technical Specification 5.5.2.16.

REFERENCES UFSAR, Section 9.1.2.2.

SAN ONOFRE--UNIT 2 B 3.7-75a Amendment No. 127

PCN-536 Attachment H (Proposed Bases Pages (For Information Only) Unit 3)

Fuel Storage Pool Boron Concentration B 3.7.17 B 3.7 PLANT SYSTEMS B 3.7.17 Fuel Storage Pool Boron Concentration BASES BACKGROUND As described in LCO 3.7.18, "Spent Fuel Assembly Storage,"

fuel assemblies are stored in the spent fuel racks in accordance with criteria based on initial enrichment, a4 discharge burnup, and cooling time (plutonium decay).

Although the water in the spent fuel pool is normally borated to e +/--85 2000 ppm, the criteria that limit the storage of a fuel assembly to specific rack locations is conservatively developed without taking credit for boron-while maintaining K,ff < 1.0. Credit for boron is taken to maintain Keff : 0.95.

APPLICABLE A fuel assembly could be inadvertently loaded into a spent SAFETY ANALYSES fuel rack location not allowed by LCO 3.7.18 (e.g., an unirradiated fuel assembly or an insufficiently depleted fuel assembly). This a.cid-rt is analyzed assuming the extreme ease of completely leading the fuel pool racks with unirradiated assemblies of maxmum erihment. Another type of postulated accident is associated with a fuel assembly that is drapped onto the fully loaded fuel pool storage rack. Either incident could have a positive reactivity effect, decreasing the margin to criticality. However, the negative reactivity effect of the soluble boron compensates for the increased reactivity caused by either one of the twe postulated accident scenarios.

Under normal, non-accident conditions, the soluble boron needed to maintain Keff less than or equal to 0.95, including uncertainties, is 970 ppm. Under accident conditions, the soluble boron needed to maintain Keff less than or equal to 0.95, including uncertainties, is 1700 ppm. A SFP boron dilution analysis shows that dilution from 2000 ppm to 1700 is not credible. Therefore, the minimum required soluble boron concentration is 2000 ppm.

The concentration of dissolved boron in the fuel pool satisfies Criterion 2 of the NRC Policy Statement.

(continued)

SAN ONOFRE--UNIT 3 B 3.7-71 Amendment No. 116

Fuel Storage Pool Boron Concentration B 3.7.17 BASES (continued)

LCO The specified concentration of dissolved boron in the fuel pool preserves the assumptions used in the analyses o-f-t-h-e potential accident scenarios described above. This concentration of dissolved boron is the minimum required concentration for fuel assembly storage and movement within the fuel pool.

APPLICABILITY This LCO applies whenever fuel assemblies are stored in the spent fuel pool. until a complete spent fuel pool verification has been performed following the last movement of fuel assemblies in the spent fuel pool. This LCO does not apply following the verifieation sinee the verification would confirm that there are no misloaded fuel assemblies.

With no further fuel assembly movements in ,prores,there is no Potental for a misloaded fuel assembly or a drepped fuel asi-ewb+

ACTIONS A.1, A.2. and A.3 The Required Actions are modified by a Note indicating that LCO 3.0.3 does not apply.

When the concentration of boron in the spent fuel pool is less than required, immediate action must be taken to preclude an accident from happening or to mitigate the consequences of an accident in progress. This is most efficiently achieved by immediately suspending the movement of fuel assemblies. This does not preclude the movement of fuel assemblies to a safe position. In addition, action must be immediately initiated to restore boron concentration to within limit. Alternately, an immediate verification, b15y administrative means, of the fuel storage pool fuel locations, to ensure proper locations of the fuel since the last moevement of fuel assemb ies in the fuel storage pool ,

can be performed.

If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operation.

Therefore, inability to suspend movement of fuel assemblies is not sufficient reason to require a reactor shutdown.

(conti nued)

SAN ONOFRE--UNIT 3 B 3.7-72 Amendment No. 116

Fuel Storage Pool Boron Concentration B 3.7.17 BASES (continued)

SURVEILLANCE SR 3.7.17.1 REQUIREMENTS This SR verifies that the concentration of boron in the spept fuel pool is within the required limit. As long as this SR is met, the analyzed incidents are fully addressed.

The 7 day Frequency is appropriate because no major replenishment of pool water is expected to take place over a short period of time.

REFERENCES 1. UFSAR, Section 9.1.

SAN ONOFRE--UNIT 3 B 3.7-73 Amendment No. 116

Spent Fuel Assembly Storage B 3.7.18 B 3.7 PLANT SYSTEMS B 3.7.18 Spent Fuel Assembly Storage BASES BACKGROUND The spent fuel storage facility is designed to store either new (nonirradiated) nuclear fuel assemblies, or burned (irradiated) fuel assemblies in a vertical configuration underwater. The storage pool is sized to store 1542 fuel assemblies. Two types/sizes of spent fuel storage racks are used (Region I and Region II). The two Region I racks each contain 156 storage locations each spaced 10.40 inches on center in a 12x13 array. Four Region II storage racks each contain 210 storage locations in a 14x15 array. The remaining two Region II racks each contain 195 locations in a 13x15 array. All Region II locations are spaced 8.85 inches on center. Ting and "flux "

construction, wher eby 11 Ithe!f assemIblie areUl, inserted inte neutron absrbing stainless steel .ans, is sufficient to m+aitain a k of - 0.95 for spent fuel of original enricehment fPt 4.1%. Hlowever, as higher initial enrichme.t feasemblies are stared intesetfuel "pol,they must be stared in a checkerbor patterýn taking into a.count fuel burnup to maintain a 0'..of or less.

To maintain Keff < 0.95 for spent fuel of nominal enrichment up to 4.8 w/o, (1) soluble boron is credited, and (2) the following storage patterns and guide tube inserts are used as needed:

(1) unrestricted storage, minimum discharge burnup and cooling time requirements vs. initial enrichment, (2) SFP Peripheral storage, minimum discharge burnup and cooling time requirements vs initial enrichment, (3) 2x2 storage patterns, minimum discharge burnup and cooling time requirements vs initial enrichment, (4) 3x3 storage patterns, minimum discharge burnup and cooling time requirements vs initial enrichment, (conti nued)

SAN ONOFRE--UNIT 3 B 3.7-74 Amendment No. 116 n7/29/99

Spent Fuel Assembly Storage B 3.7.18 BASES (continued)

BACKGROUND (5) credit for inserted Control Element Assemblies (continued) (CEAs),

(6) credit for erbia in fresh assemblies, (7) credit for cooling time (Pu-241 decay), and, (8) credit for borated stainless steel and borated aluminum guide tube inserts.

When soluble boron is credited, the following acceptance criteria apply:

(1) Under normal conditions, the 95/95 neutron multiplication factor (Keff), including all uncertainties, shall be less than 1.0 when flooded with unborated water, and, (2) Under normal and accident conditions, the 95/95 neutron multiplication factor (Keff), including all uncertainties, shall be less than or equal to 0.95 when flooded with borated water.

APPLICABLE The spent fuel storage facility is designed for SAFETY ANALYSES noncriticality by use of adequate spacing, -and"flux -- ap" construction whereby the fuel assemblies are inserted into neutron absorbing stainless steel cans--, and storage of fuel assemblies in accordance with the administrative controls in Technical Specification 5.5.2.16, "Fuel Storage Program".

The spent fuel assembly storage satisfies Criterion 2 of the NRC Policy Statement.

LCO The restrictions on the placement of fuel assemblies within the spent fuel pool, according to Figure 3.7.18 1 and Figure 3.7.18-2 Technical Specification 5.5.2.16, in the accompanying LCO, ensures that the Keff of the spent fuel pool will always remain < 0--5 1.00 under normal, non accident conditions assuming the pool to be flooded with unborated water. The Keff of the spent fuel pool will always remain < 0.95 under normal, non-accident conditions assuming the pool to be flooded with (continued)

SAN ONOFRE--UNIT 3 B 3.7-75 Amendment No. 116 7/29/9l9

Spent Fuel Assembly Storage B 3.7.18 BASES (continued)

LCO borated water with a minimum soluble boron concentration of (continued 970 ppm. The Keff of the spent fuel pool will always remain

< 0.95 under accident conditions assuming the pool to be flooded with borated water with a minimum soluble boron concentration of 1700 ppm. The restrictions are consistent with the criticality safety analysis performed for the spent fuel pool. a..ording to LCO Figure 3.7.18-1 and Figure 3.7.18 2, in the a mpn... LCO. Fuel assemblies not mfeeting the criteria of Fiuree 3.7.18 1and Figure 3.7.18 2 shall be stored in aeeardance with Speeifieation 4.3.1.1.

APPLICABILITY This LCO aoDlies whenever any fuel assembly is stored in Regions I and II of the spent fuel 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 Regions I and II of the spent fuel pool is not in accordance with iure 3.7.1.8-1. and Figure 3.7.18-2 Technical Specification 5.5.2.16, immediate action must be taken to make the necessary fuel assembly movement(s) to bring the configuration into compliance with FiHure 3.7.18 1 and Figure 3.7.18 2 Technical Specification 5.5.2.16.

If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operation.

Therefore, in either case, inability to move fuel assemblies is not sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.7.18.1 REQUIREMENTS This SR verifies by administrative means that the, i-nitial enrihment and*,urnu, f the fuel assembly is stored in accordance with Fieure 3.7.18 1 and -Fiure 3.7.18 2 Technical Specification 5.5.2.16, "Fuel Storage Program" in the accompanying LCO. For fuel assemblies in-the umaeetab 'e ra,,e of ,oure 3.7.18 1 and ,iure3.7.18-2 not stored in accordance with Technical Specification 5.5.2.16, performance of this SR will ensure comDliance with

£*pceifeatien 4.3.1.1. Technical Specification 5.5.2.16.

REFERENCES UFSAR, Section 9.1.2.2.

SAN ONOFRE--UNIT 3 B 3.7-75a Amendment No. 116

PCN-536 Attachment I (Proposed Fuel Storage Program)

SCE-2001 Page 1 of 61 Fuel Storage Program (Assuming No Boraflex)

San Onofre Nuclear Generating Station Units 2 And 3 February 2002 Southern California Edison Nuclear Fuel Division

SCE-2001 Page 2 of 61 TABLE OF CONTENTS SECTION PAGE 1.0 INTROD U CTION ......................................................... 3 2.0 ACCEPTANCE CRITERIA ................................................. 3 3.0 STORAGE OF SONGS UNITS 2 AND 3 FUEL ASSEMBLIES AND COM PONENTS ..................................................... 3 4.0 STORAGE OF SONGS UNIT 1 FUEL ASSEMBLIES ........................... 6 5.0 REFEREN CES .......................................................... 61

SCE-2001 Page 3 of 61

1. INTRODUCTION The fuel storage program(') described herein provides requirements to ensure the safe storage of fuel assemblies in the SONGS Units 2 and 3 spent fuel storage racks assuming no Boraflex, and taking credit for soluble boron in the spent fuel pool water.

The fuel storage program described in this document has NRC approval, and will not be changed or modified in any way without NRC approval.

Boraflex erosion/dissolution is an industry problem, and SONGS Units 2 and 3 are affected.

Silica levels in the SONGS Units 2 and 3 spent fuel pools are increasing, and this indicates the Boraflex is eroding/dissolving. Although there is currently sufficient Boraflex, it is prudent to plan for the long term. Taking no credit for Boraflex for SONGS Units 2 and 3 will totally eliminate any Boraflex concerns in the future, and monitoring programs to ensure that an adequate amount of Boraflex is present will not be needed.

2. ACCEPTANCE CRITERIA When credit for soluble boron is taken, the criticality acceptance criteria are:

(1) Under normal conditions, the 95/95 neutron multiplication factor (Keff), including all uncertainties, shall be less than 1.0 when flooded with unborated water.

(2) Under normal and accident conditions, the 95/95 neutron multiplication factor (Keff), including all uncertainties, shall be less than or equal to 0.95 when flooded with borated water.

3. STORAGE OF SONGS UNITS 2 AND 3 FUEL ASSEMBLIES AND COMPONENTS 3.1 SONGS Units 2 And 3 Fuel Assemblies Storage of SONGS Units 2 and 3 fuel assemblies in accordance with Tables I-1 through 11-15 and Figures 1-1 through 11-22 provides safe storage. Specifically, the spent fuel rack neutron multiplication factor (Keff) is less than 0.95 under all normal and accident conditions, including all uncertainties, provided that a minimum boron concentration of 1,700 ppm is maintained in the spent fuel pool water at all times. However, as described in Reference 2, the soluble boron concentration in the SFP must be greater than or equal to 2000 ppm to cover an accident condition and a concurrent boron dilution event.

SCE-2001 Page 4 of 61 To meet the acceptance criteria when flooded with unborated water and assuming no Boraflex, the following criteria, storage patterns and guide tube inserts, and neutron poisons have been considered:

(1) unrestricted storage, minimum discharge burnup and cooling time requirements vs initial enrichment, (2) SFP Peripheral storage, minimum discharge burnup and cooling time requirements vs initial enrichment, (3) 2x2 storage patterns, minimum discharge burnup and cooling time requirements vs initial enrichment, (4) 3x3 storage patterns, minimum discharge burnup and cooling time requirements vs initial enrichment, (5) credit for inserted Control Element Assemblies (CEAs),

(6) credit for erbia in fresh assemblies, (7) credit for cooling time (Pu-241 decay), and, (8) credit for borated stainless steel and borated aluminum guide tube inserts.

The spent fuel storage racks consist of two Regions. Region I is generally reserved for temporary storage of new fuel or partially irradiated fuel which would not qualify for Region 11 storage.

Region 1I is generally used for normal, long term storage of permanently discharged fuel that has achieved qualifying burnup levels and/or cooling times.

Region I storage patterns are given in Tables I-1 through 1-8 and Figures I-1 through 1-9.

Region 11 storage patterns are given in Tables 11-1 through 11-15 and Figures 11-1 through 11-19. Storage of fuel assemblies in accordance with these patterns ensures that Keff is less than 0.95, including all uncertainties, under all normal and accident conditions.

The analysis methodology used in Reference 1 follows NRC guidance and Westinghouse Owners Group (WOG) methodology for spent fuel storage rack criticality analysis, which have been previously reviewed and approved by the NRC.(3' 4,5,7,8) Recent methodology concerns regarding axial burnup bias(6) and equivalence of fresh fuel enrichment determined at 0 ppm being applied to cases with dissolved boron(9", have been explicitly addressed in Reference 1.

3.2 Design Requirements For Guide Tube Inserts (A) Stainless Steel guide tube inserts shall be 0.75 inches O.D. minimum, completely cover the active fuel region (150 inches), and have a minimum boron content of 0.02434 grams of B-10 per cm 3.

(B) Aluminum guide tube inserts shall be 0.75 inches O.D. minimum, completely cover the active fuel region (150 inches), and have a minimum boron content of 0.06890 grams of B-10 per cm 3.

SCE-2001 Page 5 of 61 (C) Three (3) or 5 guide tube inserts are allowed. However, when 3 guide tube inserts are used, the orientation shall be the same in every assembly in the spent fuel pool (Figure 11-20).

(D) A 5-finger, full-length Control Element Assembly (CEA) may be used in place of borated stainless steel or aluminum guide tube inserts.

3.3 Design requirements For Erbia Assemblies containing 40 or 80 erbia rods shall have the erbia rods distributed per Figures 11-21 and 11-22. The minimum initial nominal erbia loading shall be 2.0 w/o Er203.

3.4 The Failed Fuel Rod Storage Basket (FFRSB)

The Failed Fuel Rod Storage Basket (FFRSB) shall be treated as if it were an assembly with enrichment and burnup of the rod in the basket with the most limiting combination of enrichment and burnup. Alternatively, explicit analyses using the methodology of Reference 1 may be performed to determine storage requirements for the FFRSB.

3.5 Non-Fuel Components Neutron sources and non-fuel bearing assembly components (thimble plugs, CEAs, etc) may be stored in fuel assemblies without affecting the storage requirements of these assemblies. A storage basket containing no fissile material can be stored in any storage location, and can be used as a storage cell blocker for reactivity control.

3.6 Fuel Assembly Reconstitution Station A fuel assembly reconstitution station is a special case of a checkerboard pattern. A reconstitution station is permitted anywhere in the Region I racks. The empty cells in the checkerboard pattern do not need to be blocked. A reconstitution station is permitted anywhere in the Region 1Iracks provided that empty cells in the checkerboard pattern are blocked to make it impossible to misload a fuel assembly during reconstitution activities.

SCE-2001 Page 6 of 61

4. STORAGE OF SONGS UNIT 1 FUEL ASSEMBLIES (A) SONGS Unit 1 Fuel is not analyzed for storage in Region I Racks. Therefore, SONGS Unit 1 Fuel shall not be stored in Region I Racks.

(B) The burnup of each SONGS Unit 1 uranium dioxide spent fuel assembly stored in Region II shall meet the following criteria:

(1) SONGS Unit 1 nominal 3.40 w/o assemblies can be stored in the Region II Racks (unrestricted) if:

the burnup is greater than 25,000 MWD/T, and the cooling time is greater than 5 years.

(2) SONGS Unit 1 nominal 4.00 w/o assemblies can be stored in the Region II Racks (unrestricted) if:

the burnup is greater than 26,300 MWD/T, and the cooling time is greater than 20 years.

the burnup is greater than 27,100 MWD/T, and the cooling time is greater than 15 years.

the burnup is greater than 28,200 MWD/T, and the cooling time is greater than 10 years.

(3) SONGS Unit 1 nominal 4.00 w/o assemblies can be stored in the Region II Racks (SFP periphery) if:

the burnup is greater than 20,000 MWD/T, and the cooling time is greater than 0 years.

SCE-2001 Page 7 of 61 Table I-i REGION I Category I-i Fuel (Unrestricted Storage)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 22 .84 21.47 20.59 20.04 19.67 4.50 18. 61 17.57 16.89 16.45 16.17 4.00 14.30 13.58 13.09 12.78 12.57 3.50 9.84 9.40 9.11 8 .92 8.79 3 .00 5.24 5.02 4.91 4 .84 4.79 2 .47 0.00 0.00 0.00 0.00 0.00 Category Category I-i I-i Category Category I-I I-i

SCE-2001 Page 8 of 61 Table 1-2 REGION I Category 1-2 Fuel (SFP Peripheral Storage)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 12.55 12.15 11.82 11.61 11.47 4.50 9.09 8.85 8.63 8.49 8.40 4.00 5.58 5.43 5.33 5.25 5.21 3.50 2.22 2.13 2.09 2.05 2.03 3.20 0.00 0.00 0.00 0.00 0.00 P P 0 0 0 0 L

o 0 0 w

A 0 A L 0 L L 0 0 o 0 POOL WALL

SCE-2001 Page 9 of 61 Table 1-3 REGION I Category 1-3 Fuel (Filler Assembly For l-out-of-4 Pattern)

Initial Minimum Burnup (GWD/T)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 39.99 36.28 34.27 33.04 32.22 4.50 34.95 31.71 29.94 28.84 28.12 4.00 29.71 26.99 25.46 24.51 23.89 3.50 24.22 22 .03 20.79 20.02 19.52 3.00 18.37 16 .84 15 .91 15.34 14.97 2.50 12.21 11.30 10 .72 10.37 10 .13 2.00 5.28 5 .05 4.85 4.72 4.62 1.71 0.00 0.00 0.00 0.00 0.00 4.80 Category Fresh 1-3 Category Category 1-3 1-3

SCE-2001 Page 10 of 61 Table 1-4 REGION I 4.80 w/o Fresh Fuel Checkerboard Pattern Initial Minimum Burnup (GWD/T)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 4.80 0.00 0.00 0.00 0.00 0.00 4.80 Empty Fresh Empty 4.80 Fresh

SCE-2001 Page 11 of 61 Table 1-5 REGION I 4.8 w/o Fresh Fuel With Full-Length, 5-Finger CEA (Unrestricted Storage)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 4.80 0.00 0.00 0.00 0.00 0.00 4.80 4.80 Fresh Fresh With CEA With CEA 4.80 4.80 Fresh Fresh With CEA With CEA

SCE-2001 Page 12 of 61 Table 1-6 REGION I Category 1-4 Fuel (Filler Assembly For 1-out-of-4 Pattern)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 26.57 24.71 23.59 22.90 22.44 4.50 22.12 20.62 19.73 19.17 18.80 4.00 17.54 16.46 15.78 15.35 15.07 3.50 12.84 12.12 11.66 11.37 11.18 3.00 7.95 7.56 7.31 7.15 7.05 2.50 2.76 2.64 2.56 2.50 2.46 2.27 0.00 0.00 0.00 0.00 0.00 4.80 Category Fresh 1-4 80 Erbia Category Category 1-4 1-4

SCE-2001 Page 13 of 61 Table 1-7 REGION I Category I-5 Fuel (Filler Assembly For 1-out-of-4 Pattern)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 30.81 28.40 27.00 26.14 25.57 4.50 26.17 24.17 22.99 22.26 21.78 4.00 21.32 19.77 18.84 18.27 17.88 3.50 16.32 15.22 14.55 14.13 13.85 3.00 11.11 10.45 10.05 9.79 9.61 2.50 5 .55 5.30 5.14 5.04 4.98 2 .07 0.00 0.00 0.00 0.00 0.00 4.80 Category Fresh 1-5 40 Erbia Category Category 1-5 1-5

SCE-2001 Page 14 of 61 Table 1-8 REGION I Checkerboard Pattern Category 1-6 Fuel (4.80 w/o Assembly Depleted to 18.0 GWD/MTU)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 19 .82 18 .84 18.12 17.67 17.37 4.50 15 .83 15 .11 14.58 14.24 14.01 4.00 11.75 11 28 10.92 10.69 10.54 3.50 7.56 7 .23 7.04 6.91 6.83 3.00 3.28 3 .15 3.07 3'.03 2.99 2.65 0.00 0.00 0.00 0.00 0.00 Category 1-4 Fuel (Checkerboard Partner For Category 1-6 Fuel)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 26.57 24.71 23.59 22.90 22 .44 4.50 22.12 20.62 19.73 19.17 18.80 4.00 17.54 16 .46 15.78 15.35 15.07 3.50 12.84 12 .12 11.66 11.37 11.18 3.00 7.95 7.56 7.31 7.15 7.05 2.50 2.76 2 .64 2.56 2.50 2.46 2.27 0.00 0.00 0.00 0.00 0.00 Category Category 1-4 1-6 Category Category 1-6 1-4

SCE-2001 Page 15 of 61 Table II-i REGION II Category II-i Fuel (Unrestricted Storage)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 53.76 47.77 44.75 43.00 41.86 4.50 48 .43 42.93 40.15 38.52 37.47 4.00 42.91 37.94 35.40 33.92 32.96 3.00 30.99 27.26 25.30 24.16 23.43 2.00 17 .05 14.97 13.90 13.25 12.83 1.87 14 .93 13.23 12.26 11.68 11.31 1.23 0.00 0.00 0.00 0.00 0.00 Category Category II-i II-i Category Category II-i II-i Note: Category TI-i, 11-8, and 11-9 may be stored together with no restrictions.

SCE-2001 Page 16 of 61 Table 11-2 REGION II Category 11-2 Fuel (SFP Peripheral Storage)

Initial Minimum Burnup GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 36.95 33 .68 31.89 30.81 30.10 4.50 32.29 29.44 27.87 26.91 26.28 4.00 27.44 25 .04 23.70 22.88 22.35 3 .00 16.95 15 .62 14.83 14.34 14.03 2 .00 4.93 4.67 4.52 4.42 4.35 1.87 3.04 2 .87 2.76 2.69 2.64 1.70 0.00 0.00 0.00 0.00 0.00 P P 0 0 0 0 L

0 0 0 W

A 0 A L 0 L L 0 L 0 0 0 POOL WALL

SCE-2001 Page 17 of 61 Table 11-3 REGION II Checkerboard Storage Category 11-3 Fuel (Checkerboard Partner For Category 11-4 Fuel)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 41.18 37.27 35.18 33 .93 33.12 4.50 36.34 32.87 31.01 29.88 29.15 4.00 31.29 28.31 26.69 25.70 25.06 3.00 20.32 18.50 17.47 16.84 16.42 2 .00 7 .81 7.25 6.91 6.71 6.58 1 .87 5.90 5.53 5.30 5 .17 5.09 1.56 0.00 0.00 0.00 0.00 0.00 Category 11-4 Fuel (Checkerboard Partner For Category 11-3 Fuel)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 75.42 61.90 56.85 54.18 52.60 4.50 68.08 56.12 51.65 49.25 47 .76 4.00 60.74 50.35 46.44 44.19 42 .78 3.00 46.06 38.80 35.41 33.52 32.31 2.00 31.38 25.71 23.12 21.65 20.71 1.87 29.19 23.83 21.34 19.91 19.08 0.94 0.00 0.00 0.00 0.00 0.00 Category Category 11-4 11-3 Category Category 11-3 11-4

SCE-2001 Page 18 of 61 Table 11-4 REGION II Checkerboard Storage Category 11-5 Fuel (Checkerboard Partner For Category 11-6 Fuel)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 47.50 42.58 40.03 38.53 37.55 4.50 42.40 37.95 35.64 34.26 33.37 4.00 37.10 33.16 31.10 29.86 29.06 3.00 25.64 22.89 21.40 20.52 19.95 2.00 12.29 11.10 10.42 10.01 9.75 1.87 10.24 9.35 8.80 8.46 8.25 1.38 0.00 0.00 0.00 0.00 0.00 Category 11-6 Fuel (Checkerboard Partner For Category 11-5 Fuel)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 62.37 53 .95 50.33 48 .25 46.91 4.50 56.21 48 .90 45.51 43.56 42.31 4.00 50. 04 43 .67 40.54 38.73 37.57 3.00 37.71 32 .56 29.97 28.52 27.58 2.00 23.30 19 .80 18.13 17 .14 16.50 1.87 21.11 18 .02 16.42 15 .48 14.88 1.08 0.00 0.00 0.00 0.00 0.00 Category Category 11-6 11-5 Category Category 11-5 11-6

SCE-2001 Page 19 of 61 Table 11-5 REGION II Checkerboard Storage Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 4.80 0.00 0.00 0.00 0.00 0.00 4.80 Empty Fresh (Blocked)

Empty 4.80 (Blocked) Fresh

SCE-2001 Page 20 of 61 Table 11-6 REGION II Category 11-7 Fuel (3 Out Of 4 Pattern)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 34.20 31.35 29.74 28.76 28.12 4.50 29.67 27.21 25.82 24.97 24.41 4.00 24. 94 22.92 21.75 21.05 20.59 3.00 14.79 13.76 13.13 12 .73 12.47 2.00 3 .16 3.00 2.90 2 .83 2.79 1.87 1.21 1.14 1.09 1.06 1.04 1.80 0.00 0.00 0.00 0.00 0.00 Category Empty II-7 (Blocked)

Category Category 11-7 11-7

SCE-2001 Page 21 of 61 Table II-7 REGION II Category 11-8 Fuel (Fuel With 5 Guide Tube Inserts)

(Unrestricted Storage)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 37.68 34.53 32.72 31 .61 30.88 4.50 32.61 29.90 28.33 27.36 26.72 4.00 27.33 25.10 23.78 22.97 22.43 3 .00 15.86 14.76 14.06 13 .61 13.32 2.00 2.04 1.97 1.89 1.84 1.81 1.90 0.00 0.00 0.00 0.00 0.00 Category Category 11-8 II-8 Category Category 11-8 11-8 Note: Category II-1, 11-8, and 11-9 may be stored together with no restrictions.

SCE-2001 Page 22 of 61 Table 11-8 REGION II Category 11-9 Fuel (Fuel With 3 Guide Tube Inserts)

(Unrestricted Storage)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 44.16 39.95 37.68 36.31 35.42 4.50 38.99 35.25 33.22 31.99 31.18 4.00 33.61 30.38 28.60 27.52 26.81 3.00 21.92 19.86 18.72 18.01 17.56 2.00 8.28 7.72 7.34 7.11 6.96 1.87 6.18 5.83 5.58 5.43 5.34 1.59 0.00 0.00 0.00 0.00 0.00 Category Category 11-9 11-9 Category Category 11-9 11-9 Note: Category II-1, 11-8, and II-9 may be stored together with no restrictions.

SCE-2001 Page 23 of 61 Table 11-9 REGION II Category II-10 Fuel (Filler Assembly With 5 Guide Tube Inserts)

Initial Minimum Burnup (GWD/MTU)

(w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 80.09 65.66 60.12 57.45 55.68 4.50 72.13 59.43 54.55 52.02 50.33 4.00 64.18 53.19 48.98 46.58 44.98 3.00 48.27 40.72 37.16 35.03 33.75 2.00 32.35 26.59 23.79 22.25 21.25 1.03- 0.00 0.00 0.00 0.00 0.00 Category Category Category II-10 II-10 II-10 (5 Inserts) (5 Inserts) (5 Inserts)

Category 4. 80 Category II-10 II-10 (5 Inserts) Fresh (5 Inserts)

Category Category Category II-10 II-10 II-10 (5 Inserts) (5 Inserts) (5 Inserts)

SCE-2001 Page 24 of 61 Table II-10 REGION II Category II-ll Fuel (Filler Assembly With 5 Guide Tube Inserts)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 47.04 42.52 40.05 38.57 37.60 4.50 41.62 37.58 35.36 34 .02 33.14 4.00 35.97 32.46 30.50 29.32 28.54 3.00 23.70 21.42 20.09 19.31 18.79 2 .00 9.17 8.54 8.09 7.81 7.62 1.59 0.00 0.00 0.00 0.00 0.00 Category Category Category II-il II-ll II-11 (5 Inserts) (5 Inserts) (5 Inserts)

Category 4.80 Category II-ll Fresh II-11 (5 Inserts) 5 Inserts (5 Inserts)

Category Category Category II-ll II-ll II-ll (5 Inserts) (5 Inserts) (5 Inserts)

SCE-2001 Page 25 of 61 Table II-11 REGION II Category 11-12 Fuel (Filler Assembly With 3 Guide Tube Inserts)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 54 .33 48.48 45.46 43.67 42.51 4.50 48.81 43.45 40.67 39.02 37.95 4.00 43 .07 38.24 35.72 34.22 33.26 3.00 30.65 27.11 25.18 24.05 23.33 2.00 16.01 14.23 13.22 12.62 12.22 1.87 13 .82 12.35 11.47 10.94 10.60 1.32 0.00 0.00 0.00 0.00 0.00 Category Category Category 11-12 II-12 11-12 (3 Inserts) (3 Inserts) (3 Inserts)

Category 4.80 Category 11-12 Fresh 11-12 (3 Inserts) 5 Inserts (3 Inserts)

Category Category Category 11-12 II-12 11-12 (3 Inserts) (3 Inserts) (3 Inserts)

SCE-2001 Page 26 of 61 Table 11-12 REGION II Category 11-13 Fuel (Filler Assembly With No Guide Tube Inserts)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 64.24 55.51 51.59 49.41 48 .03 4.50 57.99 50.23 46.73 44.67 43.38 4.00 51.75 44.94 41.71 39.79 38.59 3.00 39.25 33.75 31.05 29.48 28.50 2.00 24.76 20.95 19.07 18.01 17 .33 1.87 22.64 19.10 17.38 16.37 15 .72 1.05 0.00 0.00 0.00 0.00 0.00 Category Category Category 11-13 I1-13 11-13 Category 4.80 Category i-i13 Fresh 1 -13 5 Inserts Category Category Category 11-13 11-13 II-13

SCE-2001 Page 27 of 61 Table 11-13 REGION II Category 11-14 Fuel (4.80 w/o Assembly Depleted to 18.0 GWD/MTU)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 19.59 18.61 17.96 17.54 17.27 4.50 15.93 15.17 14.68 14.36 14.15 4.00 12.18 11.64 11.29 11.07 10.93 3.00 4.28 4.12 4.05 4.00 3.98 2.51 0.00 0.00 0.00 0.00 0.00 Category 11-13 Fuel (Filler Assembly For Category 11-14 Fuel)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 64.24 55.51 51.59 49.41 48. 03 4.50 57.99 50.23 46.73 44.67 43.38 4.00 51.75 44.94 41.71 39.79 38.59 3.00 39.25 33.75 31.05 29.48 28.50 2.00 24.76 20.95 19.07 18.01 17.33 1.87 22.64 19.10 17.38 16.37 15.72 1.05 0.00 0.00 0.00 0.00 0.00 Category Category Category II-13 11-13 11-13 Category Category Category 11-13 11-14 11-13 Category Category Category 11-13 11-13 11-13

SCE-2001 Page 28 of 61 Table 11-14 REGION II Category 11-14 Fuel (4.80 w/o Assembly Depleted to 18.0 GWD/MTU)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 19.59 18.61 17.96 17.54 17.27 4.50 15.93 15.17 14.68 14.36 14.15 4.00 12.18 11.64 11.29 11.07 10.93 3.00 4.28 4.12 4.05 4.00 3.98 2.51 0.00 0.00 0.00 0.00 0.00 Category II-11 Fuel (Filler Assembly With 5 Guide Tube Inserts)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 47.04 42 .52 40 .05 38 .57 37.60 4.50 41.62 37 .58 35.36 34.02 33.14 4.00 35.97 32.46 30.50 29.32 28.54 3.00 23.70 21 .42 20.09 19.31 18.79 2.00 9.17 8 .54 8. 09 7.81 7.62 1.59 0.00 0.00 0. 00 0.00 0.00 Category Category Category II-ll II-ll II-ll (5 Inserts) (5 Inserts) (5 Inserts)

Category Category Category II-ll II-ll (5 Inserts) 11-14 (5 Inserts)

Category Category Category II-ll II-il II-1l (5 Inserts) (5 Inserts) (5 Inserts)

SCE-2001 Page 29 of 61 Table 11-15 REGION II Category 11-15 Fuel (Fuel With 5 Finger Full Length CEA)

(Unrestricted Storage)

Initial Minimum Burnup (GWD/MTU)

Enrichment (w/o) 0 Years 5 Years 10 Years 15 Years 20 Years Cooling Cooling Cooling Cooling Cooling 5.00 29.24 27.24 26.00 25.22 24.70 4.50 24.44 22.84 21.81 21.17 20.75 4.00 19.41 18.26 17.49 17.00 16.68 3.00 8.83 8.47 8.19 8.02 7.90 2.30 0.00 0.00 0.00 0.00 0.00 Category Category 11-15 11-15 Category Category 11-15 II-15

SCE-2001 Page 30 of 61 Figure I-i REGION I MINIMUM BURNUP FOR CATEGORY I-i FUEL 25 20 0

a.

CL 15 E 10 ci, JW U-"

5 0

2.0 2.5 3.0 3.5 4.0 4.5 5.0 Initial U-235 Enrichment (w/o)

- 0 Years - 5 Years -i- 10 Years

  • 15 Years
  • 20 Years

SCE-2001 Page 31 of 61 Figure 1-2 REGION I MINIMUM BURNUP FOR CATEGORY 1-2 FUEL 15 0

Fo E

=3 m

E co 5 i

i 0

3.0 3.5 4.0 4.5 5.0 Initial U-235 Enrichment (w/o)

-- 0 Years --e-- 5 Years - 10 Years-- 15 Years -- 20 Years

SCE-2001 Page 32 of 61 Figure 1-3 REGION I MINIMUM BURNUP FOR CATEGORY 1-3 FUEL 40 35_____

303

_ - Acceptable Region 0_ 25 _ _ _ _

=3 m 20 .

10 "U

1.5 2.0 2.5 3.0 3.5 4.0 4.5 5.0 Initial U-235 Enrichment (w/o) 0 Years 5 Years -w- 10 Years 15 Years -- H 20 Years

SCE-2001 Page 33 of 61 Figure 1-4 REGION I MINIMUM BURNUP FOR CATEGORY 1-4 FUEL 30 25 C 20 Acceptable Region CL

15 E

a)r S10 U-5 2.0 2.5 3.0 3.5 4.0 4.5 5.0 Initial U-235 Enrichment (w/o)

-S- OYears - 5Years -- l0Years -- 15 Years -- H 20 Years

SCE-2001 Page 34 of 61 Figure 1-5 REGION I MINIMUM BURNUP FOR CATEGORY 1-5 FUEL 35 30 E 25 2

0.

20

-0 15 E

<10 U

5 2.0 2.5 3.0 3.5 4.0 4.5 5.0 Initial U-235 Enrichment (w/o)

--- 0 Years -&- 5 Years - 10 Years-j- 15 Years X 20 Years

SCE-2001 Page 35 of 61 Figure 1-6 REGION I MINIMUM BURNUP FOR CATEGORY 1-6 FUEL 20 0 15 m 10 E

(n U)

FD 5 U

0 2.5 3.0 3.5 4.0 4.5 5.0 Initial U-235 Enrichment (w/o)

-+- 0 Years - 5 Years lOYears 0 -*- 15 Years -H-- 20 Years

SCE-2001 Page 36 of 61 Figure 1-7 REGION I Boundary Between All Cell Storage And Checkerboard Storage 1-1 I-1 I-1 I-1 I-1 I-1 I-1 I-1 I-I I-1 I-1 I-1 I-I I-1 I-1 I-1 I-1 1-1 1-1 Empty I-1 I-1 I-1 I-1 Empty 4.80 Empty I-1 I-1 I-1 4.80 Empty I-1 I-l I-1 I-1 II Interface I-1 1-1 I-1 I-1 1-1 I-1 1-1 I-1 I-1 I-I I-1 I-1 I-I I-I I-1 I-1 I-1 1-1 I-I 1-4 I-1 I-1 I-1 1-1 1-4 1-6 1-4 I-I I-1 1-1 1-6 1-4 I-1 I-1 I-1 I-1 II Interface Note: (1) A row of empty cells can be used at the interface to separate the configurations (2) It is acceptable to replace an assembly with an empty cell.

SCE-2001 Page 37 of 61 Figure 1-8 REGION I Boundary Between All Cell Storage And 1 Out Of 4 Storage I-1 I-1 I-1 I-1 I-1 I-1 I-1 I-1 I-1 I-1 I-1 I-1 I-1 I-1 I~-1 I-1 I-i I-1 1-3 1-3 1-3 I-1 I-1 I-1 1-3 4.80 1-3 I-1 I-1 I-1 1-3 1-3 1-3 I-1 I-1 I-1 II Interface Note: (1) A row of empty cells can be used at the interface to separate the configurations (2) It is acceptable to replace an assembly with an empty cell.

SCE-2001 Page 38 of 61 Figure 1-9 REGION I Boundary Between Checkerboard Storage And 1 Out Of 4 Storage 4.80 Empty 4.80 Empty 4.80 Empty Empty 4.80 Empty 4.80 Empty 4.80 4.80 Empty 4.80 Empty 4.80 Empty Empty 1-3 Empty 4.80 Empty 4.80 1-3 4.80 1-3 Empty 4.80 Empty 1-3 1-3 Empty 4.80 Empty 4.80 II Interface 1-6 1-4 1-6 1-4 1-6 1-4 1-4 1-6 1-4 1-6 1-4 1-6 1-6 1-4 1-6 1-4 1-6 1-4 1-3 1-3 1-3 1-6 1-4 1-6 1-3 4.80 1-3 1-4 1-6 1-4 1-3 1-3 1-3 1-6 1-4 1-6 II Interface Note: (1) A row of empty cells can be used at the interface to separate the configurations (2) It is acceptable to replace an assembly with an empty cell.

SCE-2001 Page 39 of 61 Figure 11-1 REGION II MINIMUM BURNUP FOR CATEGORY II-1 FUEL 60 1 2 3 4 5 Initial U-235 Enrichment (w/o)

-+- 0 Years e 5 Years - 10Years -;- 15 Years --- 20 Years

SCE-2001 Page 40 of 61 Figure 11-2 REGION II MINIMUM BURNUP FOR CATEGORY 11-2 FUEL 40 I Acceptable Region S30 C9 20 E

I Unacceptable Region 0I 1.5 2 2.5 3 35 A AR Initial U-235 Enrichment (w/o)

-+- 0 Years e 5 Years --- 10 Years IF 15 Years - 20 Years

SCE-2001 Page 41 of 61 Figure 11-3 REGION 1H MINIMUM BURNUP FOR CATEGORY 11-3 FUEL 50 1 "40 4 Acceptable Region S30 E

E 20 LL10 -I - - - TF-T-- -_I 1.5 2 2.5 3 3.5 4 4.5 5 Initial U-235 Enrichment (w/o)

- - 0 Years -E-- 5 Years ---- 10 Years - 15 Years -R 20 Years

SCE-2001 Page 42 of 61 Figure 11-4 REGION HI MINIMUM BURNUP FOR CATEGORY 11-4 FUEL 80.

060 CD

(.9 M40 n40

-0 C,,

E S20 IL 0

2 3 4 5

Initial U-235 Enrichment (w/o)

E9 0Years -9 5 Years -ý 10 Years -v- 15 Years i-- 20 Years

SCE-2001 Page 43 of 61 Figure 11-5 REGION II MINIMUM BURNUP FOR CATEGORY 11-5 FUEL 50 1 2 3 4 5 Initial U-235 Enrichment (w/o)

E3 0 Years -E 5 Years - 10Years I-v& 15Years -s- 20Years

SCE-2001 Page 44 of 61 Figure 11-6 REGION 11 MINIMUM BURNUP FOR CATEGORY 11-6 FUEL I 2 3 4 5 Initial U-235 Enrichment (w/o)

- -0 Years -e- 5 Years --- x 10 Years -ý- 15 Years -R 20 Years

SCE-2001 Page 45 of 61 Figure 11-7 REGION 1H MINIMUM BURNUP FOR CATEGORY 11-7 FUEL 35 .

Acceptable Region

-25 .

=20 - _.

E Cl, Q._lT

_<o , . . . .....II .* . . .÷ k _ n _

  • I 1.5 2 2.5 3 3.5 4 4.5 5 Initial U-235 Enrichment (w/o)

--- 0 Years - 5 Years --- 10 Years 5-v 15 Years -R 20 Years

SCE-2001 Page 46 of 61 Figure 11-8 REGION HI MINIMUM BURNUP FOR CATEGORY 11-8 FUEL 40 o30 CL ECD20

>i,

.0 E

]0 03 1'.5 2 2.5 3 3.5 4 4.5 5 Initial U-235 Enrichment (w/o)

E3 0 Years - 5 Years -4ý 10 Years -;-- 15 Years --- 20 Years

SCE-2001 Page 47 of 61 Figure 11-9 REGION 1[

MINIMUM BURNUP FOR CATEGORY 11-9 FUEL 50

~40 S30 (9

E 20 CD U)

"U-10 0

1.5 2 2.5 3 3.5 4 4.5 5 Initial U-235 Enrichment (w/o)

E+ 0 Years e 5 Years .--- 10 Years -vE 15 Years i+- 20 Years

SCE-2001 Page 48 of 61 Figure 11- 10 REGION II MINIMUM BURNUP FOR CATEGORY 11-10 FUEL 100 80O S60 co E 40 U-20 0-1 2 3 4 5 Initial U-235 Enrichment (w/o)

E~i OYears e 5Years -4 l0Years  :-, 15Years ER 20Years

SCE-2001 Page 49 of 61 Figure 11-11 REGION HI MINIMUM BURNUP FOR CATEGORY 11-11 FUEL 50

-*40 30 E.30 E 20 "U-10 1.5 2 2.5 3 3.5 4 4.5 5 Initial U-235 Enrichment (w/o)

Er 0 Years e 5 Years ý 10Years  ;ý; 15Years -i 20Years

SCE-2001 Page 50 of 61 Figure 11-12 REGION 11 MINIMUM BURNUP FOR CATEGORY 11-12 FUEL (40 E

m30 E

  • 20 LL 1 2 3 4 5 Initial U-235 Enrichment (w/o)

Ei 0 Years -e- 5 Years --- 10 Years ;F 15 Years -E-- 20 Years

SCE-2001 Page 51 of 61 Figure 11-13 REGION Id MINIMUM BURNUP FOR CATEGORY II-13 FUEL 70-60 50 450

  • 40 o30 E

)

CD

< 20 U

10 0--

1 2 3 4 5 Initial U-235 Enrichment (w/o)

- 0 Years E3 5 Years - 10 Years I-v 15 Years -E 20 Years

SCE-2001 Page 52 of 61 Figure 11- 14 REGION I1 MINIMUM BURNUP FOR CATEGORY 11-14 FUEL 20 015 P 10 amlO 21~

E a)

U2 2.5 3 3.5 4 4.5 5 Initial U-235 Enrichment (w/o)

E9 0 Years -e- 5 Years -- 10 Years sý, 15 Years ER 20 Years

SCE-2001 Page 53 of 61 Figure 11-15 REGION II MINIMUM BURNUP FOR CATEGORY 11-15 FUEL 30-E a)

U) 2.2 2.7 3.2 3.7 4.2 4.7 Initial U-235 Enrichment (w/o)

ý 0 Years E3 5 Years ---- 10 Years --- 15 Years Ei 20 Years

SCE-2001 Page 54 of 61 Figure 11-16 REGION 11 Boundary Between All Cell Storage And Checkerboard Storage IlI- II-1 11-1 II-1 II-1 II-1 II-1 II-1 II-1 II-1 II-1 I-I 11-1 Empty II-1 11-1 11-1 II-1 Empty 4.80 Empty 11-1 1I-1 II-1 4.80 Empty 11-1 II-1 II- J I- 1 Interface II-1 LI-1 1I-1 II-1 I-I- II-1 II-1 11-4 11-1 II-1 II-1 11-1 11-4 11-3 11-4 II-1 II-1 11-1 11-3 11-4 I1-1 IL-1 II-1 II-1 II Interface Note: (1) A row of empty cells can be used at the interface to separate the configurations (2) It is acceptable to replace an assembly with an empty cell.

SCE-2001 Page 55 of 61 Figure 11-17 REGION II Boundary Between All Cell Storage And 3 Out Of 4 Storage HI-1 111l H-1 HI-1 H-1 IH-1 H-1 1.8-1 1.8-1 1-1 11-1 1-1 II-1 H-1 11-1 11-1 11-1 II-1 Blocked 1.80 Blocked UI-1 1-t 1c-1 1.80 1.80 1.80 UI-1 111-1 1H-1 Blocked 1.80 Blocked 11-1 II1-1 11-1 Interface Note: (1) A row of empty cells can be used at the interface to separate the configurations (2) It is acceptable to replace an assembly with an empty cell.

SCE-2001 Page 56 of 61 Figure 1- 18 REGION 1I Boundary Between Checkerboard Storage And 3 Out Of 4 Storage 11-7 Blocked 11-7 Blocked 11-7 Blocked 11-7 11-7 11-7 11-7 11-7 11-7 11-7 Blocked 11-7 Blocked 11-7 Blocked Blocked 4.80 Blocked 11-7 11-7 11-7 4.80 Blocked 4.80 Blocked 11-7 Blocked Blocked 4.80 Blocked 11-7 11-7 11-7 Interface Note: (1) A row of empty cells can be used at the interface to separate the configurations (2) It is acceptable to replace an assembly with an empty cell.

SCE-2001 Page 57 of 61 Figure 11-19 REGION II Boundary Requirement For ALL 1 Out Of 9 Storage Patterns 11-1 11-1 111-1 11-1 11-1 11-1 11-1 11-1 11-1 11-1 11-1 11-1 11-1 11-1 11-1 11-1 11-1 Filler Filler Filler 11-1 11-1 11-1 Filler A Filler 11-1 11-1 11-1 Filler Filler Filler 11-1 11-1 11-1 II Interface Where: (1) If A = 4.80 w/o + 0 Inserts, Filler = Category 11-10 (2) If A = 4.80 w/o + 5 Inserts, Filler = Category 11-11 (3) If A = 4.80 w/o + 5 Inserts, Filler = Category 11-12 (4) If A = 4.80 w/o + 5 Inserts, Filler = Category 11-13 (5) If A = Category 11-14, Filler = Category 11-13 (6) If A = Category 11-14, Filler = Category 11-11

SCE-2001 Page 58 of 61 Figure 11-20 Orientation Of 3 Guide Tube Inserts

<--- Serial x Number x

xx 00 xx 00 xx xx 00 xx 00 xx XX = Guide Tube With Insert xx 00 = Empty Guide Tube 00

SCE-2001 Page 59 of 61 Figure 11-21 SONGS UNITS 2 AND 3 FUEL ASSEMBLY WITH 40 ERBIA RODS 01-i ým EE

-um I-40 Erbia Rods

- High Enriched Fuel Rod D Low Enriched Fuel Rod UI Erbia Fuel Rod

SCE-2001 Page 60 of 61 Figure 11-22 SONGS UNITS 2 AND 3 FUEL ASSEMBLY WITH 80 ERBIA RODS 80 Erbia Rods D- High Enriched Fuel Rod D Low Enriched Fuel Rod m Erbia Fuel Rod

SCE-2001 Page 61 of 61

5.0 REFERENCES

1. "Spent Fuel Pool Criticality Analysis (With No Boraflex And Credit For Soluble Boron),"

Southern California Edison Company, San Onofre Nuclear Generating Station, Units 2 And 3, Revision 0, November 2001,

2. "Spent Fuel Pool Dilution Analysis" San Onofre Nuclear Generating Station Units 2 and 3, December 2001, Southern California Edison
3. (A) Nuclear Regulatory Commission, Letter to All Power Reactor Licensees, B. K. Grimes, April 14, 1978, "OT Position for Review and Acceptance of Spent Fuel Storage and Handling Applications," as amended by the NRC letter dated January 18, 1979 (B) USNRC, Office Of Nuclear Reactor Regulation, Reactor Systems Branch, 1998, "Guidance On The Regulatory Requirements For Criticality Analysis Of Fuel Storage At Light-Water Reactor Power Plants"
4. WCAP-14416-NP-A, Rev 1, Westinghouse Electric Corporation, November 1996, "Westinghouse Spent Fuel Rack Criticality Analysis Methodology"
5. NRC Letter to Westinghouse Owners Group, October 25, 1996, "Acceptance For Referencing Of Licensing Topical Report WCAP-14416-P,

'Westinghouse Spent Fuel Rack Criticality Analysis Methodology (TAC No. M93254)'"

6. NRC To Westinghouse Letter Dated July 27, 2001 "Non-Conservatisms In Axial Burnup Biases For Spent Fuel Rack Criticality Analysis Methodology"
7. NRC to SCE Letter Dated October 3, 1996, "Issuance Of Amendment For San Onofre Nuclear Generating Station, Unit No. 2 (TAC No. M94624) and Unit No. 3 (TAC No. M94625)"
8. ANSI/ANS-57.2-1983, "American National Standard Design Requirements For Light Water Reactor Spent Fuel Storage Facilities At Nuclear Power Plants"
9. NUREG/CR-6683, ORNL/TM-2000/230, Oak Ridge National Laboratory, September 2000 "A Critical Review of the Practice of Equating the Reactivity of Spent Fuel to Fresh Fuel in Burnup Credit Criticality Safety Analyses for PWR Spent Fuel Pool Storage"