ML021210069

Duke Energy Corp. (DEC) McGuire Nuclear Station Units 1 & 2, Proposed Technical Specification on (TS) Amendments TS 3.7.15 - Spent Fuel Assembly Storage, TS 4.3 - Fuel Storage

ML021210069
Person / Time
Site:	McGuire, Mcguire
Issue date:	04/18/2002
From:	Barron H Duke Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MA9730, TAC MA9731
Download: ML021210069 (132)

Text

Duke Duke Power

• • a Company Power.

A Duk Ene e W C ompany P~ukeA Duke Energy Company McGuire Nuclear Station M G 01VP 12700 Hagers Ferry Rd.

Huntersville, NC 28078-9340 H. B. Barron Vice President, McGuire (704) 875-4800 OFFICE Nuclear Generation Department (704) 875-4809 FAX April 18, 2002 U.S. Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Duke Energy Corporation (DEC) McGuire Nuclear Station Units 1 and 2 Docket Nos. 50-369/50-370 Proposed Technical Specification (TS) Amendments TS 3.7.15 - Spent Fuel Assembly Storage, and TS 4.3 Fuel Storage

Reference:

DEC letter to NRC dated August 1, 2000 Pursuant to 10 CFR 50.90 and 10 CFR 50.4, this letter submits a license amendment request (LAR) for the McGuire Nuclear Station Facility Operating Licenses (FOL) and TSs. This amendment request is similar to a LAR previously submitted by letter dated August 1, 2000, which was approved by the NRC on November 27, 2000 (TAC NOS. MA9730 and MA9731). DEC met with the NRC in White Flint on December 11, 2001 and February 5, 2002 to address the Boraflex degradation issues, the basis for this LAR, and also DEC's corrective actions to improve the spent fuel storage issues at McGuire.

This LAR will change the McGuire TS 3.7.15 to provide revised spent fuel pool storage criteria, and revised fuel enrichment and burnup requirements which take credit for soluble boron in maintaining acceptable margins of subcriticality in the spent fuel storage pools. In addition, this LAR will' increase the required soluble boron credit from 730 ppm boron to 850 ppm boron in McGuire TS 4.3.1 to provide revised criteria for acceptable levels of subcriticality in the McGuire spent fuel storage pools. This LAR also redefines certain boundary conditions between different loading patterns of fuel assemblies. These changes are necessary to reflect the reduction of credit for Boraflex from 50% to 40% in Region 2A of the spent fuel pool and to optimize spent fuel storage configurations in the pool. This proposed amendment is applicable to Facility Operating Licenses NPF-9 and NPF-17 for the McGuire Nuclear Station.

U.S. Nuclear Regulatory Commission April 18, 2002 Page 2 provides marked up pages of the existing McGuire TSs showing the proposed changes. Attachment 2 contains the new McGuire TS pages. The Description of Proposed Changes and Technical Justification is provided in Attachment 3. Pursuant to 10CFR50.92, Attachment 4 documents the determination that this proposed amendment contains no significant hazards considerations.

Pursuant to I0CFR51.22 (c) (9), Attachment 5 provides the basis for the categorical exclusion from performing an Environmental Assessment or Impact Statement. The McGuire Spent Fuel Pool Criticality Analysis, and the McGuire Boraflex Degradation Analysis used to support this LAR are shown in Attachments 6 and 7, respectively. Also, please refer to Attachment 7 of the referenced letter for the supporting McGuire Spent Fuel Pool Dilution Analysis Summary used to support this LAR. Attachments 9 and 10 show the proposed and revised BASES for TS 3.7.14 and 3.7.15.

Implementation of this amendment to the McGuire FOLs and TSs will impact the station's UFSAR. Consequently, upon approval of this LAR, the applicable revisions will be included in a McGuire UFSAR update. These revisions will update Chapter 16 of the UFSAR, "Selected Licensee Commitments" as shown in Attachment 8. This commitment provides for periodic monitoring of future Boraflex degradation. If this monitoring determines that the Boraflex in a spent fuel storage pool has degraded to levels that would not support the conclusions of the McGuire Criticality Analysis that provides a basis for this LAR, then a future LAR would be submitted proposing additional changes to the McGuire TSs as needed to maintain acceptable levels of subcriticality in the McGuire spent fuel storage pools.

In accordance with Duke internal procedures and the Quality Assurance Program Topical Report, this proposed amendment has been previously reviewed and approved by the McGuire Station's Plant Operations Review Committee and the Duke Corporate Nuclear Safety Review Board. Pursuant to 10CFR50.91, a copy of this LAR is being forwarded to the appropriate North Carolina state officials.

In accordance with the current TSs, conservative predictions of boraflex degradation in the McGuire spent fuel pool will require numerous relocations of spent fuel assemblies prior to January 1, 2003. Consequently, DEC requests approval of this LAR by December 1, 2002 to minimize the number of relocations. As indicated in the attached "No Significant Hazards Consideration Evaluation", the proposed changes in this LAR will not result in a significant reduction in the facility's margin of safety.

U.S. Nuclear Regulatory Commission April 18, 2002 Page 3 not result in a significant reduction in the facility's margin of safety.

Please contact Norman T. Simms of Regulatory Compliance at 704 875-4685 with any questions regarding this LAR.

Very truly yours,

/ tojlýý H. B. Barron Attachments xc: (w/attachments)

L.A. Reyes Administrator, Region II U.S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA. 30303 S.M. Shaeffer NRC Senior Resident Inspector McGuire Nuclear Station R.E. Martin, Project Manager (addressee only)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop O-8G9 11555 Rockville Pike Rockville, MD 20852-2738 R.M. Fry, Director Division of Radiation Protection State of North Carolina 3825 Barrett Drive Raleigh, N.C. 27609-7221

U.S. Nuclear Regulatory Commission April 18, 2002 Page 4 H. B. Barron, being duly sworn, states that he is Vice President of McGuire Nuclear Station; that he is authorized on the part of Duke Energy Corporation to sign and file with the U.S. Nuclear Regulatory Commission these revisions to the McGuire Nuclear Station Facility Operating Licenses Nos. NPF-9 and NPF-17; and, that all statements and matters set forth therein are true and correct to the best of his knowledge.

H. B. Barron, Vice President McGuire Nuclear Station Duke Energy Corporation Subscribed and sworn to before me on /2-"A.*P, 2002.

Notary Public zlaksvait, a Threp My Commission Expires: 4A/-)0"

ý'-/

U.S. Nuclear Regulatory Commission April 18, 2002 Page 5 bxc: (w. attachments)

T.C. Geer (MG05EE)

K.L. Crane (MGO0RC)

G.D. Gilbert (CN01RC)

G.B. Swindlehurst (EC08H)

L.E. Nicholson (ON03RC)

T.M. Luniewski (MG05EE)

S.C. Ballard (MG05EE)

D.C. Jones (EC08F)

C.J. Thomas (MG01RC)

N.T. Simms (MG01RC)

ELL (EC050)

NSRB Support Staff (EC05N)

Masterfile 1.3.2.9

ATTACHMENT 1 PROPOSED REVISIONS TO THE MCGUIRE TECHNICAL SPECIFICATIONS

REPLAC E EEXT Spent Fuel Assembly Storage PAGE 3.7.15 Sf Table 3.7.15-7 (page 1 of 1)

\* ~Minimum Qualifying Burnup Versus Initial Enrichment "

/ ~ for Unrestricted Region 2A Storage '

Initial Nominal Enrichment Assembly Burnup

(% U-235) (GWD/MTU) 1.61 (or less) 0 2.00 7.79 2.50 15.14 3.00 21.45 3.50 27.42 4.00 33.00 4.50 38.32 4.75 40.91 60 I-- 50 ACCEPTABLE 04For 40 Unrestricted Storage n

Z 30 Z

j 20 UNACCEPTABLE uI For Unrestricted Storage C) 10 20) 2.00 2.50 3.00 3.50 4.00 4.50 INITIAL NOMINAL ENRICHMENT, %U-235 NOTES:

Fuel which differs from those designs used to determine the requirements of Table 3.7.15-7 may be qualified for Unrestricted Region 2A storage by means of an analysis using NRC approved methodology to assure that keff is less than 1.0 with no boron and less than or equal to 0.95 with credit for soluble boron.

McGuire Units 1 and 2 3.7.15-9 Amendment Nos.

NEW PAGE 3.7. 15-9 Spent Fuel Assembly Storage S* ~Table 3.7.15-7 (page 1 of 1) 3.7.15 S~Minimum Qualifying Burnup Versus Initial Enrichment "

S~ for Unrestricted Region 2A Storage SInitial Nominal Enrichment Assembly Burnup

(% U-235) (GWD/MTU) 1.50 (or less) 0.00 2.00 10.50 2.50 17.97 3.00 24.49 3.50 30.55 4.00 36.25 4.50 41.71 4.75 44.39 60 H- 50 ACCEPTABLE

( 40o~ 40 For Unrestricted Storage Z 30 cc

._1 20 UNACCEPTABLE LU For Unrestricted Storage C0 10 09 2.00 2.50 3.00 3.50 4.00 4.50 INITIAL NOMINAL ENRICHMENT, %U-235 NOTES:

Fuel which differs from those designs used to determine the requirements of Table 3.7.15-7 may be qualified for Unrestricted Region 2A storage by means of an analysis using NRC approved methodology to assure that keff is less than 1.0 with no boron and less than or equal

'to 0.95 with credi boron.

McGuire Units 1 and 2 3.7.15-9 Amendment Nos.

REP WPa H NIEXTP -nt Fuel Assembly Storage PAG E 3.7.15 Table 3.7.15-8 (page 1 of 1) _

Minimum Qualifying Burnup Versus Initial Enrichment for Restricted Region 2A Storage with Fillers

(% U-235) (GWD/MTU) 2.12 (or less) 0 2.50 5.10 3.00 10.88 3.50 16.19 4.00 21.07 4.50 25.81 4.75 28.11 30

-- 25 ACCEPTABLE S20 For Restricted Storage D 20 rr D

10-UNACCEPTABLE

5 For Restricted Storage C) 5 Ci) 2.00 2.50 3.00 3.50 4.00 4.50 INITIAL NOMINAL ENRICHMENT, %U-235 NOTES:

Fuel which differs from those designs used to determine the requirements of Table 3.7.15-8 may be qualified for Restricted Region 2A Storage by means of an analysis using NRC approved methodology to assure that keff is less than 1.0 with no boron and less than or equal to 0.95 with credit for soluble boron.

McGuire Units 1 and 2 3.7.15-10 Amendment Nos.

NEW 3.7 ntFuel Assembly Storage 3.7.15 Table 3.7.15-8 (page 1 of 1) x Minimum Qualifying Burnup Versus Initial Enrichment X for Restricted Region 2A Storage with Fillers Initial Nominal Enrichment Assembly Burnup

(% U-235) (GWD/MTU) 1.80 (or less) 0.00 2.00 3.70 2.50 10.30 3.00 16.10 3.50 21.70 4.00 27.00 4.50 32.10 4.75 34.50 40 D35 3 30 I" ACCEPTABLE For Rp..trict*.d Storaae 25 z 20 D

co 15 FFor Restricted Storage UNACCEPTABLE

-j 10 C/) 5 2.00 2.50 3.00 3.50 4.00 4.50 INITIAL NOMINAL ENRICHMENT, %U-235 NOTES:

Fuel which differs from those designs used to determine the requirements of Table 3.7.15-8 may be qualified for Restricted Region 2A Storage by means of an analysis using NRC approved methodology to assure that keff is less than 1.0 with no boron and less than or equal to 0.95 with credit for soluble boron.

McGuire Units 1 and 2 3.7.15-10 Amendment Nos.

REPL-ACE E NEXTt Fuel Assembly Storage PAC E 3.7.15 Initial Nominal Enrichment Assembly Burnup

(% U-235) (GWD/MTU) 1.20 (or less) 0 2.00 19.80 2.50 27.64 3.00 34.56 3.50 41.08 4.00 47.25 4.50 53.15 4.75 56.01 60 50 ACCEPTABLE For Use As Filler Assembly 40 D 30 UNACCEPTABLE 20 -

For Use As Filler Assembly In Cl) 1 2.00 2.50 3.00 3.50 4.00 4.50 INITIAL NOMINAL ENRICHMENT, %U-235 NOTES:

Fuel which differs from those designs used to determine the requirements of Table 3.7.15-9 may be qualified for use as a Region 2A Filler Assembly by means of an analysis using NRC approved methodology to aassuree that ke~f is less than 1.0 with no boron and less than or equal t0.5with cr ble boron.

McGuire Units 1 and 2 371-1AedetNs 3.7.15-11 Amendment Nos.

NEW PAGE t Fuel Assembly Storage Table 3.7.15-9 (page 1 of 1) 3.7.15 Minimum Qualifying Buru eru nitial Enrichment for Region 2A Filler Assemblies Initial Nominal Enrichment Assembly Burnup

(% U-235) (GWD/MTU) 1.15 (or less) 0.00 2.00 20.00 2.50 27.80 3.00 34.60 3.50 41.10 4.00 47.20 4.50 53.10 4.75 55.90 60

- 50 ACCEPTABLE For Use As Filler Assembly (D 40 D

CE 30 Z

UNACCEPTABLE

_J 20 For Use As Filler Assembly m.-

uJ 2.00 2.50 3.00 3.50 4.00 4.50 INITIAL NOMINAL ENRICHMENT, %U-235 NOTES:

Fuel which differs from those designs used to determine the requirements of Table 3.7.15-9 may be qualified for use as a Region 2A Filler Assembly by means of an analysis using NRC approved methodology to assure that keff is less than 1.0 with no boron and less than or equal McGuire Units 1 and 2 3.7.15-11 Amendment Nos.

Spent Fuel Assembly Storage 3.7.15 M G RESTRICTED RESTRICTED FUEL FUEL C

Restricted Fuel: Fuel which meets the minimum burnup requirements of Table 3.7.15-5, or non-fuel components, or an empty location.

Filler Location: Either fuel which meets the minimum burnup requirements of Table 3.7.15-6, or an empty cell.

Boundary Condition: rttcsnb d-'ssm,. .Ni Any Restricted Region 1 B orage Area must be separated from any other storage area by at least one row of 1 B Filler Locations or empty cells, at all boundaries between storage regions.-"

Figure 3.7.15-2 (page 1 of 1)

Required 2 out of 4 Loading Pattern for Restricted Region 1 B Storage McGuire Units 1 and 2 3.7.15-16 Amendment Nos.

Spent Fuel Assembly Storage 3.7.15 EMPTY EMPTY CELL CELL EMPTY EMPTY CELL CELL HECKERBOAR EMPTY EMPTY FUEL CELL CELL EMPTY CELL Checkerboard Fuel: Fuel which does not meet the minimum burnup requirements of Table 3.7.15-5. (Fuel which does meet the requirements of Table 3.7.15-5, or non-fuel components, or an empty location may be placed in checkerboard fuel locations as d Boundary Condition: "" , .--- '- Any Checkerboard egion Storage Area must be separated from any other storage area by at least one row of empty cells, at all boundaries between Figure 3.7.15-3 (page 1 of 1)

Required 2 out of 4 Loading Pattern for Checkerboard Region 1 B Storage McGuire Units 1 and 2 3.7.15-17 Amendment Nos.

Spent Fuel Assembly Storage 3.7.15 RESTRICTED FILLER RESTRICTED FILLER FUEL LOCATION FUEL TION FILLER RESTRICTED FILLER RESTRICTED LOCATION FUEL LOCATION FUEL RESTRICTED FILLER RESTRICTED FILLER FUEL LOCATION FUEL LOCATION FILE RSTICED FILLER RETITD LOCATION FUEL LOCATION FUEL Restricted Fuel: Fuel which meets the minimum burnup requirements of Table 3.7.15-8, or non-fuel components, or an empty location.

Filler Location: Either fuel which meets the minimum burnup requirements of Table 3.7.15-9, or an empty cell.

Boundary Condition: N ..... .. .... . ............. At least three of the four co each 2 esric e ue assembly must be adjacent to a 2A Filler Location, an empty cell, or the pool wall, at all boundaries "between storage regions.

Figure 3.7.15-4 (page 1 of 1)

Required 2 out of 4 Loading Pattern for Restricted Region 2A Storage McGuire Units 1 and 2 3.7.15-18 Amendment Nos.

Spent Fuel Assembly Storage 3.7.15 EMPTY EMPTY CELL CELL EMPTY EMPTY CELL CELL EMPTY EMPTY CELL CELL EMPTY EMPTY CELL CELL Checkerboard Fuel: Fuel which does not meet the minimum burnup requirements of Table 3.7.15-8. (Fuel which does meet the requirements of Table 3.7.15-8, or non-fuel components, or an empty location may be placed in checkerboard fuel locations as Boundary Condition: Ne t -.-----....

en a---,-,

-'" L At least three of the four

-ces ot each Checkerboard Fuel assembly must be adjacent to an empty cell or the pool wall, at all boundaries between storage region:)

Figure 3.7.15-5 (page 1 of 1)

Required 2 out of 4 Loading Pattern for Checkerboard Region 2A Storage McGuire Units 1 and 2 3.7.15-19 Amendment Nos.

Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site Location The McGuire Nuclear Station site is located at latitude 35 degrees, 25 minutes, 59 seconds north and longitude 80 degrees, 56 minutes, 55 seconds west. The Universal Transverse Mercator Grid Coordinates are E 504, 669, 256, and N 3, 920, 870, 471.

The site is in northwestern Mecklenburg County, North Carolina, 17 miles north northwest of Charlotte, North Carolina.

4.2 Reactor Core 4.2.1 Fuel Assemblies The reactor shall contain 193 fuel assemblies. Each assembly shall consist of a matrix of Zircalloy fuel rods with an initial composition of natural or slightly enriched uranium dioxide (U0 2) as fuel material. Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with approved applications of fuel rod configurations, may be used. Fuel assemblies shall be limited to those fuel designs that have been analyzed with applicable NRC staff approved codes and methods and shown by tests or analyses to comply with all fuel safety design bases. A limited number of lead test assemblies that have not completed representative testing may be placed in nonlimiting core regions.

4.2.2 Control Rod Assemblies The reactor core shall contain 53 control rod assemblies. The control material shall be silver indium cadmium (Unit 1) silver indium cadmium and boron carbide (Unit 2) as approved by the NRC.

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 4.75 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'7-0850 ppm, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR; McGuire Units 1 and 2 4.0-1 Amendment Nos.

ATTACHMENT 2 REVISED MCGUIRE TECHNICAL SPECIFICATIONS

Spent Fuel Assembly Storage 3.7.15 Table 3.7.15-7 (page 1 of 1)

Minimum Qualifying Burnup Versus Initial Enrichment for Unrestricted Region 2A Storage Initial Nominal Enrichment Assembly Burnup

(% U-235) (GWD/MTU) 1.50 (or less) 0.00 2.00 10.50 2.50 17.97 3.00 24.49 3.50 30.55 4.00 36.25 4.50 41.71 4.75 44.39 60 I- 50 C ACCEPTABLE (D 40 For Unrestricted Storage Z 30

_J 20 UNACCEPTABLE w For Unrestricted Storage

) 10

) 0 0

2.00 2.50 3.00 3.50 4.00 4.50 INITIAL NOMINAL ENRICHMENT, %U-235 NOTES:

Fuel which differs from those designs used to determine the requirements of Table 3.7.15-7 may be qualified for Unrestricted Region 2A storage by means of an analysis using NRC approved methodology to assure that keff is less than 1.0 with no boron and less than or equal to 0.95 with credit for soluble boron.

McGuire Units 1 and 2 3.7.15-9 Amendment Nos.

Spent Fuel Assembly Storage 3.7.15 Table 3.7.15-8 (page 1 of 1)

Minimum Qualifying Burnup Versus Initial Enrichment for Restricted Region 2A Storage with Fillers Initial Nominal Enrichment Assembly Burnup

(% U-235) (GWD/MTU) 1.80 (or less) 0.00 2.00 3.70 2.50 10.30 3.00 16.10 3.50 21.70 4.00 27.00 4.50 32.10 4.75 34.50 40 2

'35 S30 ACCEPTABLE For Restricted Storage z 25

D 15 UNACCEPTABLE For Restricted Storage 0

2.00 2.50 3.00 3.50 4.00 4.50 INITIAL NOMINAL ENRICHMENT, %U-235 NOTES:

Fuel which differs from those designs used to determine the requirements of Table 3.7.15-8 may be qualified for Restricted Region 2A Storage by means of an analysis using NRC approved methodology to assure that keff is less than 1.0 with no boron and less than or equal to 0.95 with credit for soluble boron.

McGuire Units 1 and 2 3.7.15-10 Amendment Nos.

Spent Fuel Assembly Storage 3.7.15 Table 3.7.15-9 (page 1 of 1)

Minimum Qualifying Burnup Versus Initial Enrichment for Region 2A Filler Assemblies Initial Nominal Enrichment Assembly Burnup

(% U-235) (GWD/MTU) 1.15 (or less) 0.00 2.00 20.00 2.50 27.80 3.00 34.60 3.50 41.10 4.00 47.20 4.50 53.10 4.75 55.90 60

'50 ACCEPTABLE For Use As Filler Assembly S40 Z 30 UNACCEPTABLE

_j 20 For Use As Filler Assembly uLJ Cl) 10 C

A . .. ý

. . . . ý I I I I II I i I i I I 2.00 2.50 3.00 3.50 4.00 4.50 INITIAL NOMINAL ENRICHMENT, %U-235 NOTES:

Fuel which differs from those designs used to determine the requirements of Table 3.7.15-9 may be qualified for use as a Region 2A Filler Assembly by means of an analysis using NRC approved methodology to assure that keff is less than 1.0 with no boron and less than or equal to 0.95 with credit for soluble boron.

McGuire Units 1 and 2 3.7.15-11 Amendment Nos.

Spent Fuel Assembly Storage 3.7.15 57 17 I Restricted Fuel: Fuel which meets the minimum burnup requirements of Table 3.7.15-5, or non-fuel components, or an empty location.

Filler Location: Either fuel which meets the minimum burnup requirements of Table 3.7.15-6, or an empty cell.

Boundary Condition: Any Restricted Region 1 B Storage Area must be separated from any other storage area by at least one row of 1B Filler Locations or empty cells, at all boundaries between storage regions.

Figure 3.7.15-2 (page 1 of 1)

Required 2 out of 4 Loading Pattern for Restricted Region 1 B Storage McGuire Units 1 and 2 3.7.15-16 Amendment Nos.

Spent Fuel Assembly Storage 3.7.15

,RE EMPTY CELL EMPTY EMPTY CELL CELL EMPTY EMPTY CELL CELL Checkerboard Fuel: Fuel which does not meet the minimum burnup requirements of Table 3.7.15-5. (Fuel which does meet the requirements of Table 3.7.15-5, or non-fuel components, or an empty location may be placed in checkerboard fuel locations as needed)

Boundary Condition: Any Checkerboard Region 1 B Storage Area must be separated from any other storage area by at least one row of empty cells, at all boundaries between storage regions.

Figure 3.7.15-3 (page 1 of 1)

Required 2 out of 4 Loading Pattern for Checkerboard Region 1B Storage McGuire Units 1 and 2 3.7.15-17 Amendment Nos.

Spent Fuel Assembly Storage 3.7.15 FILLER RESTRICTED FILLER LOCATION FUEL LOCATION RESTRICTED FILLER RESTRICTED FUEL LOCATION FUEL I FILLER LOATION RESTRICTED FUEL FILLER LOCATION RESTRICTED FILLER RESTRICTED FUEL LOCATION FUEL Restricted Fuel: Fuel which meets the minimum burnup requirements of Table 3.7.15-8, or non-fuel components, or an empty location.

Filler Location: Either fuel which meets the minimum burnup requirements of Table 3.7.15-9, or an empty cell.

Boundary Condition: At least three of the four faces of each 2A Restricted Fuel Assembly must be adjacent to a 2A Filler Location, an empty cell, or the pool wall, at all boundaries between storage regions.

Figure 3.7.15-4 (page 1 of 1)

Required 2 out of 4 Loading Pattern for Restricted Region 2A Storage McGuire Units 1 and 2 3.7.15-18 Amendment Nos.

Spent Fuel Assembly Storage 3.7.15 EMPTY EMPTY CELL CELL H

EMPTY CELL i IJ I

EMPTY EMPTY CELL CELL EMPTY EMPTY CELL CELL Checkerboard Fuel: Fuel which does not meet the minimum burnup requirements of Table 3.7.15-8. (Fuel which does meet the requirements of Table 3.7.15-8, or non-fuel components, or an empty location may be placed in checkerboard fuel locations as needed)

Boundary Condition: At least three of the four faces of each Checkerboard Fuel Assembly must be adjacent to an empty cell, at all boundaries between storage regions.

Figure 3.7.15-5 (page 1 of 1)

Required 2 out of 4 Loading Pattern for Checkerboard Region 2A Storage McGuire Units 1 and 2 3.7.15-19 Amendment Nos.

Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site Location The McGuire Nuclear Station site is located at latitude 35 degrees, 25 minutes, 59 seconds north and longitude 80 degrees, 56 minutes, 55 seconds west. The Universal Transverse Mercator Grid Coordinates are E 504, 669, 256, and N 3, 920, 870, 471.

The site is in northwestern Mecklenburg County, North Carolina, 17 miles north northwest of Charlotte, North Carolina.

4.2 Reactor Core 4.2.1 Fuel Assemblies The reactor shall contain 193 fuel assemblies. Each assembly shall consist of a matrix of Zircalloy fuel rods with an initial composition of natural or slightly enriched uranium dioxide (U0 2) as fuel material. Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with approved applications of fuel rod configurations, may be used. Fuel assemblies shall be limited to those fuel designs that have been analyzed with applicable NRC staff approved codes and methods and shown by tests or analyses to comply with all fuel safety design bases. A limited number of lead test assemblies that have not completed representative testing may be placed in nonlimiting core regions.

4.2.2 Control Rod Assemblies The reactor core shall contain 53 control rod assemblies. The control material shall be silver indium cadmium (Unit 1) silver indium cadmium and boron carbide (Unit 2) as approved by the NRC.

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 4.75 weight percent;

b. kef < 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 850 ppm, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR; McGuire Units 1 and 2 4.0-1 Amendment Nos.

ATTACHMENT 3 DESCRIPTION OF PROPOSED CHANGES AND TECHNICAL JUSTIFICATION

Attachment 3 Page 1 of 6 Description of Proposed Changes This LAR proposes a redefinition of McGuire spent fuel pool Region 2A storage, and a revision to the minimum burnup requirements for fuel assemblies stored in Region 2A. The proposed changes are described below and are based upon the reduction of the threshold amount of material in the McGuire Region 2A storage rack Boraflex panels from 50% of design minimum thickness to 40%. This threshold is being reduced to allow continued storage efficiency in Region 2 of the McGuire spent fuel pools, as a long-term solution to the Boraflex degradation issue is pursued. The evaluation of the criticality implications of this Boraflex reduction in Region 2A is documented in the revised McGuire Spent Fuel Pool Criticality Analysis (Attachment 6). The TS changes in this LAR include the following:

1. McGuire TS 4.3.1 will be revised to increase the boron concentration required to maintain keff < 0.95 from 730 ppm to 850 ppm. This increase in the boron credit requirements results from taking reactivity biases and uncertainties developed for the previous Region 2A 50% Boraflex model, and applying many of those biases and uncertainties to the new Region 2A 40% Boraflex model where convenient. This is a conservative measure, since the boron credit reactivity biases and uncertainties used in this manner increase with increasing Boraflex quantity. Note that the 850 ppm boron credit remains well below the 937 ppm boron remaining following a worst-case credible dilution event in the McGuire spent fuel pool (Attachment 7 in Reference 4).

2. McGuire TS 3.7.15 will be revised to provide revised spent fuel pool storage criteria and revised fuel enrichment and burnup requirements for McGuire Region 2A. With the applicable minimum concentration of soluble boron present in the spent fuel storage pool and reduced credit for the degraded spent fuel rack Boraflex neutron absorber panels in Region 2A, these changes will ensure that the pool storage rack keff is < 0.95 under non-accident conditions (including the unlikely occurrence of a worst-case spent fuel storage pool dilution event with thorough mixing) and accident conditions. The applicable minimum concentration of soluble boron is ensured by existing McGuire TS 3.7.14.

In the unlikely event of a worst case spent fuel storage pool dilution event without thorough mixing, the proposed changes will ensure that the pool storage rack keff is < 1.0 under non accident conditions with no credit for soluble boron and reduced credit for the degraded spent fuel rack Boraflex neutron absorber panels in Region 2A.

Attachment 3 Page 2 of 6

3. McGuire TS 3.7.15 will also be revised to require more restrictive boundary conditions between storage regions for McGuire Regions lB and 2A. Boundary conditions for Region lB are changing because of a change to the required shape of the storage configurations. Currently, Region lB storage configurations must be rows extending from one side of the rack to the other side. The proposed more restrictive storage configurations will allow storage in rectangular arrays of any size. Boundary conditions for Region 2A are changing due to the change from 50% boraflex credit to 40% boraflex credit.

As stated above, the proposed changes are based upon the assumptions of the amount of Boraflex remaining in the pools as described in the McGuire Spent Fuel Pool Criticality Analysis.

Chapter 16 of the McGuire UFSAR, "Selected Licensee Commitments",

provides for periodic monitoring of future Boraflex degradation.

If this monitoring determined that the Boraflex in a spent fuel storage pool degraded to levels that would not support the conclusions of the McGuire Spent Fuel Pool Criticality Analysis, then a future LAR would be submitted proposing additional changes to the McGuire TSs and spent fuel storage pool design bases as needed to maintain acceptable levels of subcriticality in the McGuire fuel pools.

Technical Justification Normal Conditions:

The redefined McGuire Region 2A spent fuel storage racks were analyzed taking credit for soluble boron as allowed in the NRC approved "Westinghouse Spent Fuel Rack Criticality Analysis Methodology" described in WCAP-14416-NP-A (Reference 1).

Utilizing the spent fuel pool storage configurations, spent fuel pool storage criteria, and the fuel enrichment and burnup requirements described in the McGuire Spent Fuel Pool Criticality Analysis (Attachment 6), that analysis demonstrates that under non-accident conditions a spent fuel storage pool boron concentration of 850 ppm would be adequate to maintain the spent fuel storage rack keff < 0.95 with credit for the presence of IFBA rods where applicable, and reduced credit for the degraded spent fuel rack Boraflex neutron absorber panels. Existing McGuire TS 3.7.14 states that the spent fuel pool storage boron concentrations shall be maintained within the limits specified in the McGuire Core Operating Limits Report (COLR). The spent fuel pool boron concentration limit currently specified in the COLR is 2675 ppm which is well above the minimum required boron credit of 850 ppm for non-accident conditions.

It is possible that the boron concentration in the spent fuel storage pool could be lowered below the COLR limit by a pool

Attachment 3 Page 3 of 6 dilution event. Consequently, an analysis of dilution event spent fuel storage pool boron concentrations is necessary to ensure that acceptable levels of subcriticality are maintained during and following the event (Attachment 7 in Reference 4). Note that based upon the double contingency principle, this dilution event is assumed to occur under non-accident conditions. As part of this spent fuel storage pool dilution event analysis, calculations were performed to define the dilution time and volumes for the spent fuel pool. The dilution sources available at McGuire were compiled and evaluated against the calculated dilution volume to identify the bounding dilution event. The McGuire dilution analysis concluded that the bounding event was dilution from the McGuire Recycle Holdup Tanks (RHTs) while they are in "piggy-back" alignment with the Reactor Makeup Water Storage Tank (RMWST) and the spent fuel storage pool cask loading pit is isolated and drained. Given the volume of water in these tanks and the capacity of the pumps in the flow path to a spent fuel storage pool, the dilution analysis determined that it would take over 2-11/2 days for all the water in these tanks to be added to a fuel pool. It is likely that such a worst case dilution event would be detected by a spent fuel storage pool level alarm or by plant operations personnel walking through the area before the entire volume of the RHTs and the RMWST was added to the fuel pool. Note that in the unlikely event this worst case dilution event was not detected and the entire volume of the three tanks was transferred to a fuel pool, the dilution analysis indicates that the boron concentration of a pool would be reduced to approximately 937 ppm assuming a conservative starting boron concentration of 2475 ppm and thorough mixing of the non-borated water added to a pool. This post-dilution boron concentration is well above the minimum required boron credit of 850 ppm for non accident conditions. Note that the above post-dilution event boron concentrations are based upon the assumption that all of the non-borated water added to a spent fuel pool is thoroughly mixed with the water in the pool. Given the spent fuel storage pool cooling water flow and convection from the spent fuel decay heat, it is likely that this thorough mixing would occur.

However, if mixing was not adequate, it is possible that a localized pocket of non-borated water could form somewhere in the spent fuel pool. This possibility is addressed by the calculation in Attachment 6 which shows that a spent fuel storage pool keff will still be less than 1.0 on a 95/95 basis with the spent fuel pool filled with non-borated water. Thus, in the unlikely event that the worst case dilution event occurred and then a pocket of non-borated water formed in the spent fuel pool due to inadequate mixing, acceptable subcritical conditions would still be maintained in the McGuire spent fuel storage pools.

Accident Conditions:

Many of the postulated spent fuel pool accidents at McGuire will not result in an increase in keff of the spent fuel racks. Such

Attachment 3 Page 4 of 6 accidents are the drop of a fuel assembly on top of a rack, the drop of a fuel assembly between rack modules, and the drop of a fuel assembly between rack modules and the pool wall. At McGuire, the spent fuel assembly rack configuration is such that it precludes the insertion of a fuel assembly between rack modules. The placement of an assembly between the rack and the pool wall would result in a lower keff relative to the criticality analysis due to the increased neutron leakage at the spent fuel pool wall because the criticality analysis assumes an infinite array of fuel assemblies. In the case where a dropped fuel assembly in its most reactive condition is dropped onto the spent fuel racks, it is assumed that the rack structure pertinent for criticality is not excessively deformed. For this event, previous accident analysis with unborated water showed that a dropped fuel assembly resting horizontally on top of the spent fuel rack has sufficient water separating it from the active fuel height of stored fuel assemblies to preclude neutronic interaction.

However, three accidents can be postulated which could result in an increase in reactivity in the spent fuel storage pools. The first is a drop or placement of a fuel assembly into the cask loading area. If a fuel assembly were to be dropped or placed into the cask loading area of a pool, any reactivity increase would be bounded by the fuel assembly misload accident described below. The other two postulated accidents which need to be addressed are a significant change in the spent fuel pool water temperature and the misloading of a fuel assembly. A fuel assembly misload accident relates to the use of restricted storage locations based on fuel assembly type, initial enrichment, burnup and IFBA rod loading requirements. The misloading of a fuel assembly constitutes not meeting the enrichment, burnup or IFBA rod requirements of that restricted location. The result of the misloading is to add positive reactivity, increasing keff toward 0.95. Note that special administrative controls are placed on the patterning and region loading of assemblies into these restricted locations. A significant change in the spent fuel pool water temperature can be caused by either the loss of normal cooling to the spent fuel pool water which causes an increase in the temperature of the water passing through the stored fuel assemblies or a large makeup to the pool with cold water which could happen if the spent fuel pool were used as an emergency source of borated water. The loss of spent fuel pool cooling causes a decrease in water density which would result in a decrease in reactivity when Boraflex neutron absorber panels are present in the racks.

However, since Boraflex is not considered to be present for some regions and the spent fuel pool water has a high concentration of boron, a density decrease results in a decrease in boron density which causes a positive reactivity addition. The decrease in pool temperature causes an increase in water density which would normally result in an increase in reactivity.

Attachment 3 Page 5 of 6 For each Region 2A storage configuration proposed in the revised TS 3.7.15, a McGuire spent fuel rack criticality analysis was performed as described in the McGuire Spent Fuel Pool Criticality Analysis (Attachment 6). This revised McGuire Criticality Analysis evaluated the amount of soluble boron necessary to ensure that the Region 2A spent fuel rack keff will be maintained less than or equal to 0.95 following a significant change in spent fuel pool temperature or the misloading of a fuel assembly.

For each of these accidents, that evaluation established that a minimum boron concentration of 1470 ppm is sufficient to maintain keff less than or equal to 0.95. A separate McGuire TS states that the spent fuel pool storage boron concentrations shall be maintained within the limits specified in the McGuire Core Operating Limits Report (COLR). The spent fuel pool boron concentration limit currently specified in the COLR is 2675 ppm.

Consequently, under the applicable accident conditions, maintaining spent fuel pool boron concentrations within the COLR limit will ensure that the spent fuel storage rack keff is < 0.95 when fuel is stored in accordance with the revised spent fuel pool storage configurations, revised spent fuel pool storage criteria and revised fuel enrichment and burnup requirements specified in the proposed change to TS 3.7.15. Note that, based on the double contingency principle, the margin for accident conditions included in the boron concentration limit does not have to account for both a loss of cooling accident, a misload accident, or a spent fuel pool dilution event occurring at the same time.

Conclusion Revision of the McGuire TS's and design bases as proposed in this LAR will provide a level of safety comparable to the conservative criticality analysis methodology required by References 1, 2, and 3 of this attachment. Consequently, the health and safety of the public will not be adversely affected by the proposed Technical Specification changes. The bases for these conclusions are as follows:

1. Utilizing the revised spent fuel pool storage criteria and revised fuel enrichment and burnup requirements specified in the proposed change to TS 3.7.15, the McGuire Spent Fuel Pool Criticality Analysis demonstrates that, under non-accident conditions (including thorough mixing of pool water following the unlikely occurrence of a worst case spent fuel storage pool dilution event), a minimum spent fuel storage pool boron credit of 850 ppm would be adequate to maintain the spent fuel storage rack keff < 0.95 with credit for the presence of IFBA rods where applicable and reduced credit for the degraded spent fuel rack Boraflex neutron absorber panels. This minimum boron concentration would be ensured by existing McGuire TS 3.7.14.

Attachment 3 Page 6 of 6

2. Utilizing the revised spent fuel pool storage criteria and revised fuel enrichment and burnup requirements specified in the proposed change to TS 3.7.15, the McGuire Spent Fuel Pool Criticality Analysis demonstrates that, under non-accident conditions and non-thorough mixing of pool water following the unlikely occurrence of a worst case spent fuel storage pool dilution event, spent fuel storage rack keff would remain < 1.0 with credit for the presence of IFBA rods where applicable and reduced credit for the degraded spent fuel rack Boraflex neutron absorber panels.

3. Utilizing the revised spent fuel pool storage criteria, revised fuel enrichment and burnup requirements specified in the proposed change to TS 3.7.15, the McGuire Spent Fuel Pool Criticality Analysis demonstrates that under accident conditions a minimum spent fuel storage pool boron credit of 1470 ppm would be adequate to maintain the spent fuel storage rack keff < 0.95 with credit for the presence of IFBA rods where applicable, and reduced credit for the degraded spent fuel rack Boraflex neutron absorber panels. This minimum boron concentration would be ensured by existing McGuire TS 3.7.14.

Note that the existing TS 3.7.15 specifies the requirements for spent fuel pool storage configurations, fuel pool storage criteria, fuel enrichment, and fuel burnup. Consequently, plant operating procedures already include controls to ensure these existing requirements are satisfied. These procedural controls will be revised and maintained as needed under the revised TS 3.7.15. Note that existing McGuire spent fuel pool storage systems, supporting systems, and instrumentation are not modified as a result of this proposed LAR.

References

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

2. USNRC Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, LWR Edition, NUREG-0800, June 1987.

3. USNRC Spent Fuel Storage Facility Design Bases (for Comment)

Proposed Revision 2, 1981, Regulatory Guide 1.13.

4. Proposed Technical Specification (TS) Amendments {TS 3.7.15

& TS 4.3}, Duke Energy Corporation, McGuire Nuclear Station Units 1 and 2 (Docket Nos. 50-369/50-370), August 1, 2000.

ATTACHMENT 4 NO SIGNIFICANT HAZARDS CONSIDERATION EVALUATION

Attachment 4 Page 1 of 5 No Significant Hazards Consideration Evaluation In accordance with the criteria set forth in 10 CFR 50.91 and 50.92, McGuire Nuclear Station has evaluated the proposed Technical Specification change and determined it does not represent a significant hazards consideration. The following is provided in support of this conclusion.

The radiological consequences of a fuel handling accident in the spent fuel pool do not change by taking credit for soluble boron in the pool because the current spent fuel pool boron concentration limit is not being changed. The radiological consequences also do not change as a result of reducing the minimum Region 2A rack poison requirement from 50% Boraflex remaining to 40% Boraflex remaining, because the revised Region 2A storage burnup limits still meet the required level of subcriticality for all normal and accident conditions.

1. Will the change involve a significant increase in the probability or consequence of an accident previously evaluated?

No, based upon the following:

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

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 effect on the probability of such a drop accident.

The criticality analysis showed that the consequences of a fuel assembly drop accident in the spent fuel pools are not affected when considering the degradation of the Boraflex in the spent fuel pool racks and the presence of soluble boron.

Fuel Misloading There is no significant increase in the probability of the accidental misloading of spent fuel assemblies into the spent fuel pool racks when considering the degradation of the Boraflex in the spent fuel pool racks and the presence of soluble boron in the pool water for criticality control.

Fuel assembly placement and storage will continue to be controlled pursuant to approved fuel handling procedures to

Attachment 4 Page 2 of 5 ensure compliance with the Technical Specification requirements. These procedures will be revised as needed to comply with the revised Region 2A requirements which would be imposed by the proposed Technical Specification changes.

These revised storage limits were developed with input from station personnel. Their awareness, in conjunction with any procedure changes as described above, will provide additional assurance that an accidental misloading of a spent fuel assembly should not occur.

There is no increase in the consequences of the accidental misloading of spent fuel assemblies into the spent fuel pool racks because criticality analyses demonstrate that the pool will remain subcritical following an accidental misloading if the pool contains an adequate soluble boron concentration. Current Technical Specification 3.7.14 will ensure that an adequate spent fuel pool boron concentration is maintained in the McGuire spent fuel storage pools. The McGuire Station UFSAR Chapter 16, "Selected Licensee Commitments", provides for adequate monitoring of the remaining Boraflex in the spent fuel pool racks. If that monitoring identifies further reductions in the Boraflex panels which would not support the conclusions of the McGuire Criticality Analysis, then the McGuire TSs and design bases would be revised as needed to ensure that acceptable subcriticality are maintained in the McGuire spent fuel storage pools.

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 considering the degradation of the Boraflex in the spent fuel pool racks and the presence of soluble boron in the pool water for subcriticality control since a high concentration of soluble boron has always been maintained in the spent fuel pool water. Current Technical Specification 3.7.14 will ensure that an adequate spent fuel pool boron concentration is maintained in the McGuire spent fuel storage 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 that would result in a decrease in reactivity when Boraflex neutron absorber panels are present in the racks.

However, since a reduction in the amount of Boraflex present in the Region 2A racks is considered, and the spent fuel pool water has a high concentration of boron, a density decrease causes a positive reactivity addition. However, the additional negative reactivity provided by the current

Attachment 4 Page 3 of 5 boron concentration limit, above that provided by the concentration required to maintain keff less than or equal to 0.95 (1470 ppm), will compensate for the increased reactivity which could result from a loss of spent fuel pool cooling event. Because adequate soluble boron will be maintained in the spent fuel pool water, the consequences of a loss of normal cooling to the spent fuel pool will not be increased. Current Technical Specification 3.7.14 will ensure that an adequate spent fuel pool boron concentration is maintained in the McGuire spent fuel storage pools.

A decrease in pool water temperature from a large emergency makeup causes an increase in water density that would result in an increase in reactivity when Boraflex neutron absorber panels are present in the racks. However, the additional negative reactivity provided by the current boron concentration limit, above that provided by the concentration required to maintain keff less than or equal to 0.95 (1470 ppm), will compensate for the increased reactivity which could result from a decrease in spent fuel pool water temperature. Because adequate soluble boron will be maintained in the spent fuel pool water, the consequences of a decrease in pool water temperature will not be increased. Current Technical Specification 3.7.14 will ensure that an adequate spent fuel pool boron concentration is maintained in the McGuire spent fuel storage pools.

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

No. Criticality accidents in the spent fuel pool are not new or different types of accidents. They have been analyzed in Section 9.1.2.3 of the Updated Final Safety Analysis Report and in Criticality Analysis reports associated with specific licensing amendments for fuel enrichments up to 4.75 weight percent U-235. Specific accidents considered and evaluated include fuel assembly drop, accidental misloading of spent fuel assemblies into the spent fuel pool racks, and significant changes in spent fuel pool water temperature. The accident analysis in the Updated Final Safety Analysis Report remains bounding.

The possibility for creating a new or different kind of accident is not credible. The amendment proposes to take credit for the soluble boron in the spent fuel pool water for reactivity control 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, a criticality accident resulting from a dilution accident was not considered credible. A spent fuel pool dilution evaluation (Attachment

Attachment 4 Page 4 of 5 7 in Reference 7) has 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 a revised minimum boron concentration in the spent fuel pool water for reactivity control (at least 850 ppm) will have no effect on normal pool operations and maintenance. There are no changes in equipment design or in plant configuration. This revised requirement will not result in the installation of any new equipment or modification of any existing equipment.

Therefore, the proposed amendment will not result in the possibility of a new or different kind of accident.

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

No. The proposed Technical Specification changes and the resulting McGuire Region 2A spent fuel storage operating limits will provide adequate safety margin to ensure that the stored fuel assembly array will always remain subcritical. Those revised limits are based on a plant specific criticality analysis (Attachment 6) based on the "Westinghouse Spent Fuel Rack Criticality Analysis Methodology" described in Reference 1. The Westinghouse methodology for taking credit for soluble boron in the spent fuel pool has been reviewed and approved by the NRC (Reference 6). This methodology takes partial credit for soluble boron in the spent fuel pool and requires conformance with the following NRC acceptance criteria for preventing criticality outside the reactor:

1) keff shall be less than 1.0 if fully flooded with unborated water which includes an allowance for uncertainties at a 95% probability, 95% confidence (95/95) level; and

2) keff shall be less than or equal to 0.95 if fully flooded with borated water, which includes an allowance for uncertainties at a 95/95 level.

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 keff will be less than 1.0 with no soluble boron. Soluble boron credit is used to provide safety margin by maintaining kff 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 substantial amounts of soluble boron from the spent fuel

Attachment 4 Page 5 of 5 pool which could lead to exceeding a keff of 0.95 has been evaluated (Attachment 7 in Reference 7) and shown to be not credible. Accordingly, the required margin to criticality is not reduced.

Previous evaluations (Attachment 7 in Reference 7) have shown that the dilution of the spent fuel pool boron concentration from the conservative assumed initial boron concentration (2475 ppm) to the minimum boron concentration required to maintain keff < 0.95 (850 ppm) is not credible.

The dilution analyses, along with the 95/95 criticality calculation which shows that the spent fuel rack keff will remain less than 1.0 when flooded with unborated water, provide a level of safety comparable to the conservative criticality analysis methodology required by References 2, 3 and 4.

Therefore, the proposed changes in this license amendment will not result in a significant reduction in the facility's margin of safety.

References

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

2. USNRC Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, LWR Edition, NUREG-0800, June 1987.

3. USNRC Spent Fuel Storage Facility Design Bases (for Comment)

Proposed Revision 2, 1981, Regulatory Guide 1.13.

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

5. Attached McGuire Criticality Analysis and other attached documentation (including references therein) forming the basis for this license amendment request.

6. Letter from TE Collins (NRC) to T Greene (WOG), Acceptance for Referencing of Licensing Topical Report WCAP-14416-P, "Westinghouse Spent Fuel Rack Criticality Analysis Methodology." (TAC No. M93254), Dated October 15, 1996.

7. Proposed Technical Specification (TS) Amendments {TS 3.7.15

& TS 4.3}, Duke Energy Corporation, McGuire Nuclear Station Units 1 and 2 (Docket Nos. 50-369/50-370), August 1, 2000.

ATTACHMENT 5 ENVIRONMENTAL IMPACT ASSESSMENT

Attachment 5 Page 1 of 1 Environmental Impact Assessment:

The proposed Technical Specification amendment has been reviewed against the criteria of 10 CFR 51.22 for environmental considerations. The proposed amendment will allow credit to be taken for soluble boron in the spent fuel storage pool water to maintain an acceptable margin of subcriticality for redefined Region 2A fuel storage limits. Appropriate controls are in place to monitor the soluble boron concentration in the spent fuel pool water and to monitor for future degradation of the Boraflex panels in the spent fuel storage cells. Consequently, 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.

ATTACHMENT 6 MCGUIRE SPENT FUEL POOL CRITICALITY ANALYSIS

Attachment 6 Page 1 of 44 MCGUIRE SPENT FUEL POOL CRITICALITY ANALYSIS Table of Contents Section Page

1.0 INTRODUCTION

2 1.1 Spent Fuel Pool Storage Rack Design 3 1.2 New Fuel Storage Vault Design 4 2.0 COMPUTER CODES AND METHODOLOGY 5 3.0 CRITICALITY ANALYSIS 7 3.1 No Boron 95/95 keff 8 3.1.1 No Boron 95/95 keff - Burnup Credit 11 3.1.2 No Boron 95/95 keff - IFBA Credit 13 3.2 Boron Credit 95/95 keff 14 3.3 New Fuel Storage Vault Analysis 17 3.4 Conditions Outside the Storage Rack 18 4.0 ACCIDENT CONDITIONS 20 5.0 BORON CREDIT

SUMMARY

22 6.0 REGION INTERFACE RESTRICTIONS 23 7.0

SUMMARY

OF RESULTS 25

8.0 REFERENCES

26

Attachment 6 Page 2 of 44

1.0 INTRODUCTION

This attachment describes the criticality analysis of the McGuire Nuclear Station spent fuel storage racks. This analysis takes credit for soluble boron in the spent fuel pool water as allowed in Reference 8.1 of this attachment.

It should be noted that the Westinghouse methodology in Reference 8.1 was used as the basis for the methodology used in this analysis. However, since this analysis was performed by Duke Energy, some minor differences in the application of the methodology exist. For example, this analysis used a different set of computer codes to perform the calculations (as described in Section 2.0) instead of those described in Reference 8.1. So, while the process and criteria defined in the "Westinghouse Spent Fuel Rack Criticality Analysis Methodology" were followed, the methodology used for this submittal, which is based on the Westinghouse methodology, is described in this attachment.

The storage rack design for the McGuire spent fuel pools is a two region design. Each region utilizes the poison material Boraflex. Due to the degradation of the Boraflex poison material and the need to establish acceptable spent fuel storage limits, each region has been divided into two sub-regions; with and without credit for Boraflex. For the regions taking credit for Boraflex, a minimum amount of Boraflex was assumed that is less than the original design minimum B 1 0 areal density. The sub regions are defined as follows:

"* Region 1A takes credit for 25% of the original Boraflex material

"* Region lB takes no credit for Boraflex

"* Region 2A takes credit for 40% of the original Boraflex material

"* Region 2B takes no credit for Boraflex Within each sub-region, the criticality analysis takes credit for burnup and storage configuration restrictions to achieve acceptable spent fuel storage limits. Two storage configurations are defined for each of the four regions: Unrestricted and Restricted storage. A third loading pattern, Checkerboard storage, was defined for Regions 1B, 2A and 2B. Unrestricted storage allows storage in all cells without restriction on the storage configuration. Restricted storage allows storage of higher reactivity fuel when restricted to a certain storage configuration with lower reactivity fuel. Checkerboard storage allows storage of the highest reactivity fuel in each region when checkerboarded with empty storage cells.

Attachment 6 Page 3 of 44 In addition, credit is also taken for Integrated Fuel Burnable Absorbers (IFBAs). IFBA credit is only taken for Region 1A since this is the region where the new fuel will be stored prior to refueling the reactor.

The main design criteria for the McGuire spent fuel storage rack criticality analysis is that keff < 1.0 with no boron (including tolerances and uncertainties) and keff < 0.95 with credit for soluble boron. The soluble boron credit required for the storage configurations in all regions is 850 ppm for normal conditions and 1470 ppm for accident conditions.

1.1 Spent Fuel Storage Rack Design McGuire has two independent identical spent fuel pools for Units 1 and 2. The spent fuel storage rack in each pool consists of a two-region design.

The Region 1 area of the spent fuel pools is designed and generally reserved for temporary storage of new or partially irradiated fuel which would not qualify for storage in the Region 2 area. The storage cell configuration in this region represents a less reactive array than that of Region 2. The stainless steel cells are spaced at 10.4 inches and were constructed with a minimum 0.02 gm/cm2 loading of B1 0 neutron absorbing material attached to the exterior cell wall wrapper plate. Region 1 has a capacity which is just sufficient to accommodate both a complete off load of the reactor core and storage of a reload fuel batch.

With the larger fuel batch sizes to accommodate McGuire's 18 month cycle lengths, there are very few unused cells in Region 1 during an outage.

The basic spent fuel storage pool rack arrangement for Units 1 and 2 is shown in Figure 1. The Region 1 area of the pool is highlighted and a schematic of the Region 1 cell configuration is also provided.

The Region 2 area of the spent fuel pools is designed and generally used for normal, long term storage of permanently discharged fuel that has achieved qualifying burnup levels. The storage cell configuration in this region represents a more reactive array than that of Region 1. The stainless steel cells are assembled in a checkerboard pattern, producing a honeycomb structure of "cell" and "non-cell" locations. This configuration has a much tighter center-to-center pitch of 9.125 inches. These cells also utilize a neutron absorbing material with a slightly lower minimum B1 0 areal density (0.006 gm/cm2 ) than that used in Region 1. This region has a nominal capacity of 1177 locations.

Attachment 6 Page 4 of 44 The basic spent fuel storage pool rack arrangement for Units 1 and 2 is shown again in Figure 2 with the Region 2 area of the pool highlighted and a schematic of the Region 2 cell configuration provided.

1.2 New Fuel Storage Vault Design The new fuel storage vaults which are used for temporary dry storage of unirradiated reload fuel are built on 21 inch centers and are currently licensed for maximum nominal fuel enrichments of 4.75 %U-235. To accommodate a new Westinghouse Performance Plus fuel design, previously approved analytical methods were used to demonstrate that this new fuel containing up to 4.75% U 235 can be safely stored in these fuel racks. No other restrictions beyond this enrichment limit are applicable to storage in the new fuel vaults. Discussion of the methods used to justify this increased limit can be found in Section 3.3. No technical specification changes are applicable to the new fuel storage vaults.

Attachment 6 Page 5 of 44 2.0 COMPUTER CODES AND METHODOLOGY The methodology employed in this analysis is based on the "Westinghouse Spent Fuel Rack Criticality Analysis Methodology" (Reference 8.1). While, the process and criteria defined in the Westinghouse methodology were followed, the methodology used for this submittal, which is based on the Westinghouse methodology, is described in this attachment.

The methodology employed in this analysis uses both the CASMO 3/TABLES-3/SIMULATE-3 and SCALE system of codes for criticality analysis. CASMO-3/TABLES-3/SIMULATE-3 is used primarily and SCALE with KENO-Va is used for limited applications.

The burnup credit approach to fuel rack criticality analysis requires calculation and comparison of reactivity values over a range of burnup and initial enrichment conditions. In order to accurately model characteristics of irradiated fuel which impact reactivity, a criticality analysis method capable of evaluating arrays of these irradiated assemblies is needed. In this license submittal, the advanced nodal methodology combining CASMO 3/TABLES-3/SIMULATE-3 is used for this purpose. CASMO-3 is an integral transport theory code, SIMULATE-3 is a nodal diffusion theory code, and TABLES-3 is a linking code which reformats CASMO-3 data for use in SIMULATE-3. This methodology permits direct coupling of incore depletion calculations and resulting fuel isotopics with out-of-core storage array criticality analyses. The CASMO-3/TABLES-3/SIMULATE-3 methodology has been previously approved for use in criticality analysis of the McGuire spent fuel storage racks (Reference 8.2).

The CASMO-3/TABLES-3/SIMULATE-3 methodology is validated by comparison to measured results of fuel storage critical experiments. The criticality experiments used to benchmark the methodology were the Babcock and Wilcox close proximity storage critical experiments performed at the CX-10 facility (Reference 8.3). The B&W critical experiments used are specifically designed for benchmarking reactivity calculation techniques. The criticality experiments examined have similar nuclear characteristics to spent fuel storage and are applicable to conditions encountered during the handling of LWR fuel outside reactors.

The results of the CASMO-3/TABLES-3/SIMULATE-3 benchmark calculations are shown in Table 1. There are no significant trends in the results with respect to moderator soluble boron concentration, array spacing, or boron level in the isolation sheets.

Attachment 6 Page 6 of 44 The SCALE system of computer codes was used to model the Checkerboard storage configurations, new fuel storage vault and various biases and uncertainties related to the Boraflex material (self shielding, shrinkage and gaps). This methodology utilizes three dimensional Monte Carlo theory. Specifically, this analysis method used the CSAS25 sequence contained in Criticality Analysis Sequence No. 4 (CSAS4). CSAS4 is a control module contained in the SCALE-4.2 system of codes. The CSAS25 sequence utilizes two cross section processing codes (NITAWL and BONAMI) and a 3-D Monte Carlo code (KENO-Va) for calculating the effective multiplication factor for the system. The 27 Group NDF4 cross section library was used exclusively for this analysis.

The KENO-Va methodology is also benchmarked to measured results of fuel storage critical experiments. The criticality experiments used to benchmark the KENO-Va methodology were from the PNL reports PNL-3314 (Reference 8.4), PNL-2438 (Reference 8.5) and PNL-6205 (Reference 8.6). The criticality experiments examined have similar nuclear characteristics to spent fuel storage and are applicable to conditions encountered during the handling of LWR fuel outside reactors.

The results of the KENO-Va benchmark calculations are shown in Table 2. There are no significant trends in the results with respect to fuel pin spacing, array spacing, poison loading and material or fuel enrichment.

For additional verification that the models used in the McGuire criticality analysis are accurate, calculated keffS from CASMO-3, SIMULATE-3 and KENO-Va are compared in Table 3. The results listed in Table 3 show very good agreement between the transport theory, diffusion theory and Monte Carlo codes, with CASMO-3 and SIMULATE-3 being slightly conservative compared to KENO-Va.

Attachment 6 Page 7 of 44 3.0 CRITICALITY ANALYSIS This section describes the criticality analysis performed to determine the spent fuel storage limits for the McGuire spent fuel storage racks.

The following assumptions are used in the spent fuel pool criticality analysis.

1. All fuel designs stored, or planned for storage, at McGuire were analyzed. This included Westinghouse Standard (STD),

Optimized (OFA) and Robust Fuel (RFA, also referred to as Performance Plus or PF+) and Framatome Mark BW (MkBW) fuel designs. Also included were the Oconee fuel assemblies currently stored at McGuire. All fuel designs are analyzed for all cases and only the most reactive fuel design is used to set the storage requirements.

2. All conditions are modeled at both 68 and 150 'F. Only the most reactive temperature is used to set the storage requirements.

3. Most calculations are 2-D; i.e. no axial effects are modeled.

A reactivity bias is included in the 2-D calculations to account for differences between 2-D and 3-D modeling.

4. No xenon conditions are assumed in the storage racks.

5. No credit is taken for the spacer grid material.

6. McGuire Region 1A contains 25% of its original thickness and areal density.

7. McGuire Region lB contains no Boraflex.

8. McGuire Region 2A Boraflex contains 40% of its original thickness and areal density.

9. McGuire Region 2B contains no Boraflex.

10.The Boraflex panels are reduced in the width direction to account for 0.25 inches assumed shrinkage.

ll.The Boraflex panels are reduced in the axial direction to account for measured shrinkage.

12.No reactivity penalty is included for gaps in the Boraflex panels (see Section 3.1).

13.The nominal coating on IFBA rods is assumed to be 1.OX which

Attachment 6 Page 8 of 44 is the minimum standard loading offered by the vendor. The IFBA coating is reduced to 75% of this value to account for the IFBA coating not being applied for the full length of the fuel rod.

3.1 No Boron 95/95 keff This section describes the methodology used to determine the limits for the keff calculation with no boron including all biases and uncertainties (95/95 keff).

The 95/95 keff must be less than 1.0 with no boron. The calculation of the 95/95 keff must consider various biases and uncertainties related to the materials and construction of the racks. Specifically, the biases and uncertainties accounted for in the McGuire spent fuel pool criticality analysis are the bias and uncertainty associated with the benchmarking of the methodology, biases and uncertainties associated with the affect of Boraflex shrinkage, a bias to account for the underprediction of reactivity due to self shielding, a bias to account for 3 dimensional effects not captured by the 2-dimensional model and the uncertainty due to mechanical tolerances from the manufacturing process. The mechanical tolerance uncertainty is comprised of the following components: cell ID, CTC spacing, cell thickness, Boraflex width, plenum thickness, enrichment, fuel pellet dish volume, fuel pellet theoretical density, fuel pellet OD, clad OD and assembly position within the storage cell. For the no boron 95/95 keff, these biases and uncertainties are generated at no boron conditions. Additional uncertainties related to burned fuel are discussed with the burnup credit methodology. Table 4 lists the biases and uncertainties for each region.

The uncertainties associated with the effect of Boraflex shrinkage include the following. A reactivity bias is included to account for an assumed 0.25 inches of shrinkage in the width of the Boraflex panels. A reactivity uncertainty is included to account for the 95/95 worst case shrinkage in the axial direction (end pullback of the top and bottom). No reactivity penalty is included to account for gaps in the middle of the Boraflex panels, nor are any gaps included in the models. However, an analysis was performed to determine the maximum gap size before an increase in reactivity occurs. This analysis looked at a gap in one out of four panels, two out of four and four out of four panels. The results of this analysis indicate that the size gap required before an increase in reactivity is observed is less than the size of gaps observed in recent measured data. Hence, no reactivity penalty is necessary to account for gaps in the

Attachment 6 Page 9 of 44 Boraflex panels.

A no boron 95/95 maximum design keff is defined to be 1.0 less the combination of all the biases and uncertainties. For the final keff to remain less than 1.0, the calculated keff must remain less than the no boron maximum design keff. Since the combined biases and uncertainties are dependent on the fuel storage rack, four no boron 95/95 maximum design keffs are defined, one for each region of the pool. These maximum design keffS are listed in Table 4.

To determine the maximum enrichment for Unrestricted storage, CASMO-3 is used to iterate on enrichment until the calculated keff from CASMO-3 meets the no boron 95/95 maximum design keff. Since CASMO-3 is a lattice code, its calculations are for single assemblies in an infinite array, which is representative of the Unrestricted 100% storage option. The results of the fresh fuel limits for Unrestricted storage are summarized in Table 6.

Assemblies which do not qualify for unrestricted storage must be stored in a restricted storage configuration. Two restricted storage configurations are employed; Restricted storage with low reactivity 'filler' assemblies in a specified storage pattern and Checkerboard storage with empty cells in a specified storage pattern.

For Restricted storage to be effective, the storage requirements must be carefully selected to optimize the use of the spent fuel storage cells for the current and expected inventory of fuel for each region. For this reason, a different Restricted storage pattern is defined for each region of the McGuire spent fuel pools. For Region IA, a 3 out of 4 storage pattern is defined which allows assemblies not qualified for Unrestricted storage to be stored in 3 out of every 4 locations with the 4 th being a qualified low reactivity 'filler' assembly. This storage pattern is shown in Figure 3. For Regions IB and 2A, two different checkerboard storage patterns are defined which allow assemblies not qualified for Unrestricted storage to be stored in 2 out of every 4 locations with the other 2 being qualified low reactivity

'filler' assemblies. This storage pattern is shown in Figure 4.

For Region 2B, a 1 out of 4 storage pattern is defined which allows assemblies not qualified for Unrestricted storage to be stored in 1 out of every 4 locations with the other 3 being qualified low reactivity 'filler' assemblies. This storage pattern is shown in Figure 5. By storing the more reactive assemblies not qualified for Unrestricted storage with less reactive fuel, the overall reactivity of the array is able to stay beneath the no boron 95/95 maximum design keff. The Unrestricted and Restricted storage patterns for each region will allow optimum usage of all the storage cells in the McGuire racks

Attachment 6 Page 10 of 44 for a wide range of fuel assemblies.

Prior to performing any reactivity calculations, the requirements of either the filler or restricted assemblies must be selected.

In this analysis, the requirements for the restricted assemblies were selected first and the filler requirements were then calculated for the restricted assembly requirements chosen. The fresh fuel limits defined for Restricted storage are summarized in Table 6.

The maximum enrichment for the Filler fuel in the Restricted storage configurations is calculated using SIMULATE-3. To model the Restricted storage patterns, the model must have the ability to analyze different assemblies in the same problem. This required the nodal code. SIMULATE-3 was executed to calculate keff of the Restricted storage array containing dissimilar fuel.

The maximum enrichment for the filler fuel is determined by iterating on enrichment until the calculated keff from SIMULATE-3 meets the no boron 95/95 maximum design keff. The results of the fresh fuel limits for Filler fuel in the Restricted storage configuration are summarized in Table 6.

Assemblies which do not qualify for Unrestricted or Restricted storage must be stored in a checkerboard storage pattern with empty storage locations. Checkerboard storage will allow storage of all fuel in each region.

The goal of Checkerboard storage is to be able to store the most reactive fuel assembly in each region. This is accomplished by storing the most reactive assembly with empty storage locations to keep the overall reactivity of the array beneath the required reactivity limit. To determine the storage pattern for Checkerboard storage, the calculated keff is varied by varying the number of empty cells until the calculated keff is less than or equal to the maximum design keff. The calculated keffs are taken from KENO-Va. A different Checkerboard storage pattern is defined for each region of the McGuire spent fuel pools. Since restricted storage for Region 1A includes fuel up to the maximum allowed enrichment, Checkerboard storage is not necessary for this region. The Checkerboard storage patterns are shown in Figures 6 and 7.

While it is intended to use the Unrestricted and Restricted storage patterns for optimum usage of all the storage cells, Checkerboard storage allows storage of the most reactive fuel in all regions if it becomes necessary.

Attachment 6 Page 11 of 44 3.1.1 No Boron 95/95 keff -Burnup Credit In order to store fuel with enrichments higher than the maximum enrichment limits for fresh fuel, the concept of reactivity equivalencing is employed. Reactivity equivalencing determines an equivalent reactivity by introducing a reactivity effect that was not previously considered. In this case, the negative reactivity from fuel burnup is used to offset the positive reactivity from higher enrichments until the reactivity is equivalent to that of the fresh fuel maximum enrichment case (i.e. the no boron 95/95 maximum design keff).

To use burnup credit, additional uncertainties related to depleted fuel must also be accounted for. The only burnup related uncertainty included in the no boron 95/95 maximum design keff calculation is the reactivity increase associated with the removal of Burnable Poison assemblies (BP-pull). All other burnup related uncertainties, namely the uncertainty on the calculated reactivity versus burnup, the uncertainty on the measured burnup and the bias related to the axial distribution of burnup will be accounted for with boron credit as discussed in Section 3.2.

A bias is applied in the burnup credit calculations to account for a reactivity increase due to the shadowing effect of a BP.

For burnup credit calculations, the standard criticality assumption was made that no removable poisons are in the assembly. However, an assembly which has a BP removed after its first cycle of operation is more reactive than an assembly that never contained a BP. A BP-pull bias is applied to account for this affect. A study of a database of BP-pull data for McGuire determined a maximum BP-pull reactivity increase of 0.01 Ak at 14 GWD/MTU. The bias is assumed to be linear from 0 GWD/MTU to the maximum bias at 14 GWD/MTU and is constant beyond 14 GWD/MTU.

This is conservative because the reactivity of the BP-pulled assembly tends to approach the reactivity of the never BP'd assembly by EOL. For burnup credit calculations, the bias only needs to be applied for assemblies with burnup. Hence, for Unrestricted storage burnup credit calculations, CASMO-3 is used and hence, the entire bias is applied, since every assembly has burnup. For the SIMULATE-3 model used for the Restricted storage calculations, only the Filler fuel has burnup. The Restricted fuel is modeled as fresh fuel with the maximum enrichments from Table 6. Therefore, an appropriate ratio of the BP-pull bias is applied for the Restricted storage array since only part of the array has burnup.

Summarizing, the BP-pull bias for each region is as follows.

Attachment 6 Page 12 of 44 O.OlxBU bias Unrestricted Storage All Regions BP-pull 14 bias= 0.0025xBU Restricted Storage Region IA EP-pull 14 lB BP-pull bias= 0.005xBU Restricted Storage Region 0.00514xBU bias=

Restricted Storage Region 2A BP-pull 14 0.0075xBU Restricted Storage Region 2B BP-pull bias=

14 Where: BU = Assembly burnup in GWD/MTU up to a maximum of 14 To model fuel burnup, CASMO-3 was used to deplete the fuel under hot full power reactor conditions. CASMO-3 restarts were then performed to model the depleted assemblies in the storage racks.

This ensures the reactivity of the depleted assembly is explicitly determined in the storage rack conditions. CASMO-3 restarts are performed at 5 GWD/MTU intervals from 0 to 60 GWD/MTU and at 0.5 w/o enrichment intervals from 2.0 to 4.5 w/o and the maximum enrichment of 4.75 w/o. A TABLES-3 library was also created from the CASMO-3 storage rack restart data to allow modeling the burned fuel in SIMULATE-3.

The burnup credit calculations are performed similar to the calculations that determined the maximum fresh fuel enrichments except that instead of varying the enrichment, the burnup is varied. As with the maximum fresh fuel enrichment calculations, for Unrestricted storage, the calculated keffS come from CASMO-3, specifically, the storage rack restart cases with burned fuel.

For Restricted storage, the calculated keffS come from SIMULATE-3.

The calculated keffs are used to determine minimum burnup limits for each enrichment to ensure that the 95/95 storage rack keff is

< 1.0. The burnup limit is the burnup where the calculated keff equals the no boron maximum design keff from Table 4 minus the appropriate BP-pull bias discussed above. The minimum burnup requirements for each enrichment are determined by linearly interpolating between the calculated burnups. This linear interpolation assumes that the calculated keff vs. burnup curve is linear. This is a very good assumption over small ranges of burnup.

The minimum burnup requirements for each enrichment are then plotted versus burnup and enrichment to yield a storage curve. A separate storage curve is generated for each type of storage and each region. A fuel assembly qualifies for storage if its burnup and enrichment fall above the storage curve.

Attachment 6 Page 13 of 44 The results of the burnup credit calculations are summarized in Tables 7 through 9. The storage curves are shown in Figures 8 and 9.

3.1.2 No Boron 95/95 keff -IFBA Credit This section describes the methodology for reactivity equivalencing taking credit for integrated fuel burnable absorber (IFBA) rods. IFBA rods are fuel rods with a thin layer of ZrB2 sprayed on the fuel pellet. This coating provides a reactivity holddown at beginning of cycle. For the criticality analysis, this coating provides an integral poison in the fuel that may be taken credit for in the analysis. Credit for normal burnable poison rods is not allowed since these poison components can be removed from the fuel assembly.

In order to store fresh fuel more efficiently, the concept of reactivity equivalencing is employed. Reactivity equivalencing determines an equivalent reactivity by introducing a reactivity effect that was not previously considered. In this case, IFBA rods are introduced into the calculation and the enrichment is varied until the calculated keff is equivalent to that of the fresh fuel maximum enrichment case (i.e. the no boron 95/95 maximum design keff).

Credit for IFBA is only utilized in Region 1A, where the fresh fuel is to be stored. The reactivity of Regions lB, 2A and 2B are such that there is no real benefit for IFBA credit since these regions will not typically store fresh fuel. The use of IFBA credit for fresh fuel in Region 1A will permit most of the fresh fuel to be stored within the limited number of locations available in this region.

The calculated keffs come from the infinite lattice code CASMO-3.

The calculated keffs are used to determine maximum enrichment for each discrete number of IFBA rods to ensure that the 95/95 storage rack keff is < 1.0. The maximum enrichment requirements for each number of IFBA rods are determined by iterating on enrichment until the calculated keff is less than the no boron 95/95 maximum design keff.

The maximum enrichment requirements for each number of IFBA rods are then plotted versus enrichment and number of IFBA rods to yield an Unrestricted storage curve. A fuel assembly qualifies for Unrestricted storage if its enrichment and number of IFBA rods fall above the Unrestricted storage curve. Assemblies which fall below the Unrestricted storage curve must be stored in a Restricted loading pattern.

Attachment 6 Page 14 of 44 The results of the IFBA credit calculations are summarized in Table 10.

3.2 Boron Credit 95/95 keff This section describes the methodology used to determine the amount of soluble boron required to maintain the 95/95 keff <

0.95. The soluble boron required consists of two components; the boron required to reduce the no boron 95/95 keff from 1.0 to 0.95 and the boron required to account for uncertainties in the reactivity equivalencing methods. The sum of these two components of required boron represent the amount of soluble boron credit needed. This required boron concentration must be less than the amount of boron available for normal conditions.

The amount of boron available for normal conditions is determined from an appropriate boron dilution analysis. Additional boron requirements are needed to compensate for reactivity increases as a result of postulated accidents. These are discussed in the Section 4.

Just as with the no boron 95/95 keff calculation, the calculation of the soluble boron credit 95/95 keff must consider various biases and uncertainties related to the materials and construction of the racks. The same biases and uncertainties for the no boron 95 percent probability at a 95 percent confidence level keff are determined for the soluble boron credit 95/95 keff calculation. The only difference in the calculation of the uncertainties is that the calculations are now performed with the boron concentration required to maintain keff less than 0.95.

Only the mechanical tolerance uncertainty was explicitly calculated with boron. Given the extremely small change in the uncertainty between no boron and boron conditions, and the significant amount of margin available in the amount of boron available, the Boraflex related uncertainties were not recalculated at boron conditions. Table 5 lists the boron credit biases and uncertainties for each region.

The soluble boron credit 95/95 maximum design keff is then 0.95 less these biases and uncertainties. For the final keff to remain less than 0.95, the calculated keff must remain less than the boron credit maximum design keff. Since the combined biases and uncertainties are dependent on the fuel storage rack, four boron credit 95/95 maximum design keffs are defined, one for each region of the pool. These maximum design keffs are listed in Table 5.

To determine the boron concentration required for keff < 0.95, SIMULATE-3 is used to iterate on the boron concentration using the appropriate fresh fuel enrichment for each region until the

Attachment 6 Page 15 of 44 calculated keff from SIMULATE-3 is less than the soluble boron credit 95/95 maximum design keff. Two sets of cases are run for each region for Unrestricted and Restricted storage. The appropriate fresh fuel enrichments for each case are the maximum fresh fuel enrichments for Unrestricted and Restricted storage in each region shown in Table 6. This establishes the first part of the total soluble boron credit required without accidents.

In addition to the boron credit required to maintain keff < 0.95, boron credit is also used to compensate for uncertainties associated with the reactivity equivalencing methods. Two reactivity equivalencing methods are used in this analysis; burnup credit and IFBA credit.

For burnup credit, the uncertainties associated with this reactivity equivalencing method are as follows:

Burnup Credit Uncertainties Calculated reactivity and depletion versus burnup Measured burnup Axial burnup distribution The BP-pull reactivity increase is not included in the boron credit determination since it is already accounted for in the burnup limits.

Previous analysis for McGuire fuel determined an exposure reactivity bias of 0.0048 Ak at 50 GWD/MTU to be applied linearly versus burnup. However, a more conservative value will be used which is consistent with other boron credit analyses. A value of 0.01 Ak at 30 GWD/MTU applied linearly versus burnup will be used for the calculated reactivity uncertainty.

To determine the amount of boron credit required for the uncertainty in the calculation of burnup, the burnup credit reactivity bias is determined for the highest burnup requirement from the fuel storage curves for each region. SIMULATE-3 is then run to iterate on the boron concentration until the keff is equal to the keff with no boron, less the burnup credit reactivity bias.

The uncertainty on measured burnup is 4%. This is the measurement uncertainty applied to the 2-D power distribution (FDH). This is conservative because the burnup is simply the power distribution integrated over time. Thus, to assume a burnup uncertainty of 4% is to assume the measured power distribution was low by 4% for its entire depletion history, when in reality it is low at times and high at other times.

Attachment 6 Page 16 of 44 To determine the amount of boron credit required for the measurement uncertainty on burnup, the highest burnup requirement from the fuel storage curves for each region is determined. The highest burnup requirement is then reduced by 4%. SIMULATE-3 is then run to iterate on the boron concentration until the keff with 4% reduced burnup is equal to the keff with the highest burnup (i.e. not reduced) and no boron.

Since the criticality calculations used to define the spent fuel storage limits are performed in 2-dimensions, a flat axial burnup distribution is inherent in the 2-D modeling. An analysis performed to study the effect of a 3-D burnup distribution determined that ignoring the effect of the axial variation in burnup on the criticality calculation becomes non-conservative as burnup increases. This analysis determined biases for each sub region as a function of enrichment and burnup to be applied to account for the potential non-conservatism from not modeling the axial burnup distribution. The axial burnup distribution bias is then interpolated to the appropriate burnups of the assemblies in the specific problem.

To determine the amount of boron credit required to properly account for the axial burnup distribution, the axial burnup distribution bias is determined for the highest burnup requirements from the fuel storage curves for each region.

SIMULATE is then run to iterate on the boron concentration until the keff is equal to the keff with no boron, less the axial burnup distribution bias.

For IFBA credit, the uncertainties associated with this reactivity equivalencing method are as follows:

IFBA Credit Uncertainties Manufacturing uncertainty Calculational uncertainty The manufacturing uncertainty applied is a 5% decrease in the B 1 0 loading on the IFBA rods. To determine the amount of boron credit needed for the manufacturing uncertainty on IFBA rods, the highest number of IFBA rods required for storage is determined.

CASMO-3 is then run to calculate the keff with B1 0 loading reduced by 5%. The boron concentration is iterated on until the keff with the reduced B 1 0 loading is equal to the keff with the normal loading and no boron.

The calculational uncertainty applied is a 10% decrease in the number of IFBA rods. To determine the amount of boron credit needed for the calculational uncertainty on IFBA rods, the highest number of IFBA rods required for storage is determined.

Attachment 6 Page 17 of 44 In this case, the IFBA requirements for 4.75 w/o fuel are interpolated from the previous IFBA results to determine a specific number of IFBA rods required, instead of one of the discrete number of IFBA rod configurations available. This specific number of IFBA rods is reduced by 10% and then rounded down to the nearest number of IFBA rods available. CASMO-3 is then run to calculate the keff with this number of IFBA rods. The boron concentration is iterated on until the keff with the reduced number of IFBA rods is equal to the no boron 95/95 maximum design keff.

Note that the IFBA credit uncertainties are only calculated for restricted storage in Region 1A since IFBA credit is not used for any other storage limits.

The boron credit requirements are summarized in Table 11.

3.3 New Fuel Storage Vault Analysis The new fuel vaults at the McGuire Nuclear Station are designed exclusively for temporary storage of fresh unirradiated fuel.

The ANSI/ANS-57.3 Design Standard simply requires that keff be maintained at less than or equal to 0.95 under fully flooded conditions and less than or equal to 0.98 assuming optimum moderation. Analysis used to determine keff in these storage racks must therefore assume maximum allowable fuel enrichments.

Criticality control relies strictly on the wide spacing between individual storage locations and a specified upper limit for as built fuel enrichment. The absence of other factors such as soluble boron, fixed poisons, burnup effects and fission products makes for a relatively straightforward analysis. The normally dry condition of the fuel vaults introduces the possibility of water intrusion. Consequently, full density water flooding was conservatively modeled as a base condition in this analysis.

Other less likely events which could create low density moderator conditions (i.e. foaming, misting, etc.) dictated analysis of optimum moderator conditions as an accident condition. Vault criticality analysis is therefore performed as a function of both enrichment and moderator density.

KENO-Va was used to calculate the keff for 4.75 %U-235 nominal enrichment for vault storage. The analysis assumed a 100% cell loading pattern and consequently, no loading pattern restrictions are needed or applicable in the new fuel storage vault.

The following assumptions are used in the new fuel storage vault criticality analysis.

1. All fuel designs used, or planned for use, at McGuire were

Attachment 6 Page 18 of 44 analyzed. This included Westinghouse Standard (STD),

Optimized (OFA) and Performance Plus (PF+) and Framatome Mark BW (MkBW) fuel designs.

2. All calculations are 3-D. The upper and lower fuel assembly nozzles are ignored.

3. All fuel is fresh unirradiated.

4. No credit is taken for the spacer grid material.

The calculated worst-case keffs for fully flooded and optimum moderation conditions for a fuel assembly with the maximum nominal enrichment of 4.75 %U-235 are:

Fully Flooded Maximum keff = 0.9433 Optimum Moderation Maximum keff = 0.9759 These values were for the Westinghouse Performance Plus fuel design which was the most reactive of all fuel types analyzed.

This value also includes geometrical and material uncertainties and biases at a 95 percent probability and a 95 percent confidence level as required to demonstrate criticality safety.

The uncertainties considered include:

Embedded concrete tolerances Fuel Cage tolerances As specified in ANSI/ANS 57.3, the maximum keff value in a LWR new fuel storage vault shall be less than or equal to 0.98 under optimum moderator conditions and less than or equal to 0.95 under fully flooded conditions. The analytical results shown above indicate that these criteria have been met.

3.4 Conditions Outside the Storage Rack This section briefly describes the evaluation of the reactivity conditions of fuel located anywhere outside of the storage rack.

Fuel is first received in shipping containers approved for use under 10CFR Part 71 and need not be considered any further.

After the fuel is received it may be loaded into the new fuel storage vault which is discussed in Section 3.3.

The fuel is transferred from the new fuel vault into a new fuel elevator where it is lowered into the spent fuel pool such that the fuel handling crane can access it to place it in a storage cell. The most limiting condition from a criticality standpoint

Attachment 6 Page 19 of 44 during this process is the fuel assembly in water with no poison.

As discussed in Section 3.1, keff must be less than 1.0 with no boron. This condition has been analyzed and it was determined that it would require a fresh fuel enrichment much greater than 5.0 w/o to approach a keff of 1.0 for a single assembly surrounded by water. As discussed in Section 3.2, keff must be less than or equal to 0.95 with credit for soluble boron. KENO is run to iterate on the boron concentration to determine the required boron to maintain keff < 0.95. To simplify this calculation, the calculation is performed at 4.80 w/o, instead of 4.75 w/o and all other fuel parameter uncertainties are neglected except the method bias and uncertainty determined in Table 2. The boron credit requirements for a single assembly in water are compared to the boron requirements determined as described in Section 3.2 and the more restrictive of the two will is used. This is because the boron requirements for the single assembly in water are independent of the boron requirements in Section 3.2. As can be seen from the results in Table 11, the single assembly in water case is well bounded by the boron credit required from Section 3.2.

The fuel is stored in the spent fuel storage cell until it is ready to be loaded into the reactor. At that point, the fuel handling crane moves the assembly into the upender, where it is then lowered to a horizontal position for transfer into the reactor building via the fuel transfer tubes. While the upender and fuel handling crane contain some amount of steel, and hence poison material, these conditions are bounded by the single assembly in water case.

Another possible location of fuel is in any reconstitution or inspection equipment. Criticality considerations for these scenarios are addressed by a 50.59 evaluation covering the use of the equipment for the intended purpose. Also included in this would be storage of failed fuel in special canisters or racks.

The only other possible places to have a fuel assembly would be as a result of an accident, i.e. dropping an assembly where it is not supposed to be. These conditions are covered by either the single assembly in water condition described in this section, or in Section 4.0.

Therefore, all possible locations of a fuel assembly inside the McGuire Nuclear Station are acceptable for up to and including 4.75 w/o for all analyzed fuel designs.

Attachment 6 Page 20 of 44 4.0 ACCIDENT CONDITIONS As part of the criticality analysis for the McGuire spent fuel pools, abnormal and accident conditions are considered to verify that acceptable criticality margin is maintained for all conditions. Most accident conditions will not result in an increase in keff of the rack. However, accidents can be postulated which would increase the reactivity of the spent fuel pool. These accidents must be analyzed to verify acceptable criticality safety margin exists. Since boron is used to compensate for reactivity increases as a result of postulated accidents, acceptable criticality safety margin exists if the total boron requirements are less than the normal concentration in the storage pool water.

The most severe accident in terms of criticality would be the misloading of an assembly; in particular, misloading the highest reactive assembly allowed in the pool in place of the lowest reactive assembly. This accident would be the substitution of a fresh 4.75 w/o assembly for a required filler assembly.

Since the SIMULATE-3 models for the McGuire storage racks consist of a 2x2 array reflected with periodic boundary conditions, the substitution of a fresh 4.75 w/o assembly for a required filler assembly will be extremely conservative since this accident condition will be infinitely reflected. A more realistic representation of this accident would be to model a larger array, and misloading a single assembly near the center of this array.

However, since substantial criticality margin exists, the overly conservative 2x2 array will be sufficient.

Other accidents which could have an impact on reactivity in the spent fuel pool are those that affect the water temperature of the spent fuel pool. Accidents could be postulated which would either increase or decrease the temperature of the spent fuel pool. Therefore, to bound the range of temperatures of the spent fuel pool water, the accident analysis considers water temperatures of 32 and 212 OF.

The above accident conditions are analyzed and the boron concentration is iterated upon until the calculated keff is less than the no boron 95/95 maximum design keff. This boron concentration, combined with the boron concentration for boron credit 95/95 keff from Section 3.2 represents the total credit for boron that is required for accident conditions. This total boron requirement must be less than the normal spent fuel pool boron concentration.

Note that by combining the boron required for accidents with the

Attachment 6 Page 21 of 44 boron required to maintain keff < 0.95 (i.e. the boron credit 95/95 maximum design keff), the accident conditions are imposed on top of the dilution accident for the total boron requirements.

However, accident conditions are not assumed with no boron conditions. This is consistent with previous criticality analysis methodology where the double contingency principle is applied for accidents. The double contingency principle allows credit for soluble boron under other abnormal or accident conditions, since only a single accident need be considered at one time and to not assume the presence of some boron would be a second unlikely event. The difference with the boron credit methodology is that, for added assurance that sufficient criticality safety margin exists, the dilution of the pool with perfect mixing to 937 ppm is assumed to be a credible event.

The additional boron credit requirements for accident conditions are summarized in Table 11.

Attachment 6 Page 22 of 44 5.0 BORON CREDIT

SUMMARY

This analysis takes partial credit for soluble boron in the spent fuel pool for both normal and accident conditions. Boron credit is used to compensate for uncertainties related to reactivity equivalencing and accident conditions. The total boron credit requirements for each region are shown in Table 11. The total boron credit requirements for the entire McGuire spent fuel pool are then the highest values from all regions as follows:

Boron Credit Boron Required Available Normal 850 937' Conditions Accident 1470 26752 Conditions

- From dilution analysis 2 -current limit specified in the Core Operating Limits Report 6.0 REGION INTERFACE RESTRICTIONS Fuel will be stored in four regions of the spent fuel pool according to three different loading configurations. The boundary conditions between these configurations are analyzed to assure that the storage configurations at the boundary do not cause an increase in the nominal keff above the design criteria limit on keff for the individual regions. This analysis is performed to determine if there is a need for new administrative restrictions at the boundaries. The results of this analysis yield the following region interface restrictions.

Attachment 6 Page 23 of 44 Region Interface Restrictions Region lA Unrestricted No restrictions Storage Region lA Restricted Any Restricted Region 1A Storage Area row Storage bounded by any other storage area shall contain a combination of restricted fuel assemblies and filler locations such that no restricted fuel assemblies are adjacent to each other. Example: In Figure 3, row 1 or column 1 can not be adjacent to another storage area, but row 4 column 4 can be.

Region lB Unrestricted No restrictions Storage Region lB Restricted Any Restricted Region lB Storage Area must Storage be separated from any other storage area by at least one row of IB Filler Locations or empty cells, at all boundaries between storage regions.

Region lB Checkerboard Any Checkerboard Region lB Storage Area Storage must be separated from any other storage area by at least one row of empty cells, at all boundaries between storage regions.

Region 2A Unrestricted No restrictions Storage Region 2A Restricted At least three of the four faces of each Storage Restricted Fuel assembly must be adjacent to a 2A Filler Fuel assembly, an empty cell, or the pool wall, at all boundaries between storage regions.

Region 2A Checkerboard At least three of the four faces of each Storage Checkerboard Fuel assembly must be adjacent to an empty cell or the pool wall, at all boundaries between storage regions.

Region 2B Unrestricted No restrictions Storage Region 2B Restricted Any Restricted 2B Storage Area row bounded Storage by any other storage area shall contain only filler locations arranged such that no Restricted Fuel assemblies are adjacent to any other fuel except Region 2B Filler Locations. Example: In Figure 5, row 1 or column 1 can not be adjacent to another storage area, but row 4 or column 4 can be.

Attachment 6 Page 24 of 44 Region 2B Checkerboard Any Checkerboard Region 2B Storage Area Storage row bounded by any other storage area shall contain only empty cells arranged such that no Checkerboard Fuel assemblies are adjacent to any fuel. Example: In Figure 7, row 1 or column 1 can not be adjacent to another storage area, but row 4 or column 4 can be.

Attachment 6 Page 25 of 44 7.0

SUMMARY

OF RESULTS The results of the criticality analysis for the McGuire spent fuel storage racks indicate that the acceptance criteria for criticality is met; that is keff < 0.95 including uncertainties.

The two region rack design is subdivided within each region for cells with credit for Boraflex and cells without credit for Boraflex. This analysis takes credit for soluble boron, partial credit for Boraflex in Regions IA and 2A, no credit for Boraflex in Regions lB and 2B, credit for burnup and credit for IFBA rods.

Each of the four regions has two storage configurations, Unrestricted and Restricted storage. Three regions (Regions 1B, 2A and 2B) have an additional Checkerboard configuration that allows the most reactive fuel to be stored.

The spent fuel storage limits are summarized in Tables 6 through 10 and Figures 3 through 9.

The total boron credit requirements for these configurations in all regions are 850 ppm for normal conditions and 1470 ppm for accident conditions.

Also, the acceptability of storing the new Westinghouse Performance Plus fuel design in the new fuel storage vaults is verified.

Attachment 6 Page 26 of 44

8.0 REFERENCES

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

8.2 "Issuance of Amendments - McGuire Nuclear Station, Units 1 and 2," Amendment Nos. 159 and 141 to Facility Operating Licenses NPF-9 and NPF-17, U.S. Nuclear Regulatory Commission, November 6, 1995.

8.3 Baldwin, Hoovler, Eng, and Welfare, "Critical Experiments Supporting Close Proximity Water Storage of Power Reactor Fuel", B&W-1484-7, 7/79.

8.4 Beirman, S.R., Clayton, E.D., "Criticality Experiments with Subcritical Clusters of 2.35 and 4.31 wt% 235U Enriched U02 Rods in Water at a Water to Fuel Volume Ratio of 1.6" PNL 3314, July 1980.

8.5 Beirman, S.R. , et al, "Critical Separation Between Subcritical Clusters of 2.35 wt% 235U Enriched U02 Rods in Water with Fixed Neutron Poisons" PNL-2438, October 1977.

8.6 Beirman, S.R., "Criticality Experiments to Provide Benchmark Data on Neutron Flux Traps" PNL-6205, June 1988.

Attachment 6 Page 27 of 44 Table 1 CASMO-3/TABLES-3/SIMULATE-3 Benchmarking Results Core Soluble Moderator Separation Poison keff calc keff meas Bias Boron Temp Spacing Sheet (cm) (%B) 2 1037 18.5 0 n/a 1.00271 1.0001 -0.00261 3 764 18 1.636 n/a 1.00319 1.0000 -0.00319 9 0 17.5 6.544 n/a .99908 1.0030 0.00392 10 143 24.5 4.908 n/a .99795 1.0001 0.00215 11 514 26 1.636 SS 1.00493 1.0000 -0.00493 13 15 20 1.636 1.614 1.00914 1.0000 -0.00914 14 92 18 1.636 1.257 1.00451 1.0001 -0.00441 15 395 18 1.636 0.401 .99608 0.9988 0.00272 17 487 17.5 1.636 0.242 .99889 1.0000 0.00111 19 634 17.5 1.636 0.1 1.00003 1.0002 0.00017 avg 1.00165 st.dev 0.00412 k calc calc avg keff 1.000231 avg bias 1-0.00142 meas CASMO-3/TABLES-3/SIMULATE-3 Methodology Bias = -0.00142 CASMO-3/TABLES-3/SIMULATE-3 Methodology Uncertainty = 0. 01199

Attachment 6 Page 28 of 44 Table 2 KENO-Va Benchmarking Results Exp. Calculated Exp. Calculated Report Number keff std dev Report Number keff std dev PNL-3314 043 0.99991 0.00295 PNL-3314 085 0.98979 0.00354 PNL-3314 045 0.9984 0.00335 PNL-3314 094 0.99568 0.00383 PNL-3314 046 0.9999 0.0033 PNL-3314 095 0.99914 0.004 PNL-3314 047 1.00532 0.00346 PNL-3314 096 0.99908 0.00349 PNL-3314 048 1.00083 0.00326 PNL-3314 097 0.99731 0.00342 PNL-3314 04c 0.99727 0.00317 PNL-3314 098 0.99494 0.00353 PNL-3314 051 1.00114 0.00392 PNL-3314 100 0.99621 0.00378 PNL-3314 053 0.99105 0.0035 PNL-3314 101 0.99799 0.00391 PNL-3314 055 0.99502 0.00409 PNL-3314 105 0.99911 0.00339 PNL-3314 056 0.99249 0.0038 PNL-3314 106 0.99323 0.00353 PNL-3314 057 0.99603 0.00317 PNL-3314 107 0.99812 0.00302 PNL-3314 058 0.99613 0.00321 PNL-3314 131 0.99708 0.00379 PNL-3314 059 0.99233 0.00377 PNL-3314 996 1.0115 0.00304 PNL-3314 060 0.99657 0.00362 PNL-3314 997 1.00775 0.00305 PNL-3314 061 0.99331 0.00371 PNL-2438 005 0.9923 0.00348 PNL-3314 062 0.9954 0.00418 PNL-2438 014 0.99212 0.00321 PNL-3314 064 0.98736 0.00351 PNL-2438 015 0.99207 0.00301 PNL-3314 065 0.99728 0.00392 PNL-2438 021 0.99119 0.00302 PNL-3314 066 0.9942 0.00374 PNL-2438 026 0.99218 0.00314 PNL-3314 067 0.99153 0.00374 PNL-2438 027 0.99396 0.00312 PNL-3314 068 0.99169 0.00333 PNL-2438 028 0.99092 0.00322 PNL-3314 069 0.99684 0.00396 PNL-2438 029 0.99366 0.00319 PNL-3314 06d 1.00645 0.004 PNL-2438 034 0.99596 0.00323 PNL-3314 070 0.98921 0.00369 PNL-2438 035 0.98911 0.00317 PNL-3314 071 0.99405 0.00342 PNL-6205 214 0.99117 0.00353 PNL-3314 072 0.98865 0.00356 PNL-6205 223 0.99726 0.0038 PNL-3314 073 0.98801 0.00343 PNL-6205 224 0.99329 0.00388 PNL-3314 083 0.99043 0.00341 PNL-6205 229 1.00119 0.00355 PNL-3314 084 0.99366 0.00364 PNL-6205 230 1.00031 0.00406 Average keff = 0.99559 KENO-Va Methodology Bias = 0.00441 KENO-Va Methodology Uncertainty = 0.00739

Attachment 6 Page 29 of 44 Table 3 CASMO-3 / SIMULATE-3 / KENO Va Comparisons Fuel Fuel CASMO Simulate KENO Rack Region Enrichment Type keff keff keff MNS Region 1A 4.0 mbw .97661 .976666 .96827 (25% of original Boraflex)

MNS Region 1B 4.0 mbw 1.18568 1.185535 1.17930 (No Boraflex)

MNS Region 2A 1.4 mbw .94030 .94033 .93791 (40% of original Boraflex)

MNS Region 2B 1.4 mbw 1.06701 1.06701 1.06233 (No Boraflex) I

Attachment 6 Page 30 of 44 Table 4 CASMO / SIMULATE No Boron Biases and Uncertainties for Fresh Fuel Region Region Region Region Bias or Uncertainty 1A 1B 2A 2B Methodology Bias* -0.00142 -0.00142 -0.00142 -0.00142 Boraflex Width Shrinkage Bias 0.005405 0 0.00202 0 Self-Shielding Bias 0.002141 0 0.000712 0 3 Dimensional Bias* -0.00158 -0.00252 -0.00202 -0.00295 95/95 Methodology Uncertainty 0.01199 0.01199 0.01199 0.01199 Boraflex Axial Shrinkage 0.002595 0 0.00010 0 Uncertainty Mechanical Uncertainty 0.015923 0.018729 0.00804 0.010993 Combined Bias and Uncertainty 0.027647 0.022238 0.01717 0.016267 No Boron 95/95 Maximum Design 0.972353 0.977762 0.98283 0.983733 keff Combined Bias and Uncertainty:

Ak = AkMethBias + AkWidth + AkSelfShielding + Ak 3 Dimensional + V'Ak4ethUnc + Ak Axial + Ak MechUnc Negative bias conservatively ignored For KENO-Va calculations, the above methodology bias and uncertainty are replaced with the KENO-Va methodology bias and uncertainty (Table 2) and the KENO-Va calculated uncertainty is included under the radical.

Attachment 6 Page 31 of 44 Table 5 CASMO / SIMULATE Boron Credit Biases and Uncertainties for Fresh Fuel Bias or Uncertainty Region Region Region Region lA lB 2A 2B Methodology Bias* -0.00142 -0.00142 -0.00142 -0.00142 Boraflex Width Shrinkage Bias 0.005405 0 0.00202 0 Self-Shielding Bias 0.002141 0 0.000712 0 3 Dimensional Bias* -0.00158 -0.00252 -0.00202 -0.00295 95/95 Methodology Uncertainty 0.01199 0.01199 0.01199 0.01199 Boraflex Axial Shrinkage 0.002595 0 0.00010 0 Uncertainty Mechanical Uncertainty 0.015912 0.019684 0.008911 0.010922 Combined Bias and Uncertainty 0.027638 0.023049 0.01767 0.016266 Boron Credit 95/95 Maximum 0.922362 0.926951 0.93233 0.933734 Design keýff Combined Bias and Uncertainty:

2 2 Ak = AkmethBias + AkWidth + Ak selfshieldng + Ak 3 Dimensional + VAk2MethUnc + AkiAxial + AkkMechUnc

• Negative bias conservatively ignored

Attachment 6 Page 32 of 44 Table 6 Summary of Maximum Fresh Fuel Enrichment Limits (w/o U-235)

Type of Storage Region Region Region Region 1A lB 2A 2B Unrestricted 3.78 1.78 1.50 1.11 Restricted 4.75 2.20 1.80 1.22 Filler 1.76 1.44 1.15 1.08 Checkerboard N/A 4.75 4.75 4.75

Attachment 6 Page 33 of 44 Table 7 Minimum Qualifying Burnup versus Initial Enrichment For Unrestricted Storage Region IA Region 1B Region 2A Region 2B Initial ..................

Minimum

• r~t...i Initial B urnu ......... Enric Minimum mem . ..............

... .P........... Initial

}3.....h n... ...... Minimum

. Initial . . .. .Minimum B u ............

En.

............ B uu-...

Enrichment BuWMup Enrichment BuMup Enrichment Bu(Mup Enrichment Bumup (w/o U-235))! (GWDIMTIJ) (w/6 U-235)) (GWD/MTIJ) (w/o U-235)) (GWDIMTIJ) (w/o U-235)) (GWD/MTU) 3.78 1 0.00 1.78 0.00 1.50 0.00 1.11 0.00 4.00 1 1.58 2.00 3.96 2.00 10.50 2.00 21.58 4.50 4.92 2.50 11.35 2.50 17.97 2.50 29.00 4.756.66 3.00 1.13.00 2.93.00 35.69 3.50 23.35 3.50 30.55 3.50 41.97 4.00 28.86 4.00 5 36.25 4.00 47.90 4.50 34.10 4.50 41.71 4.50 53.57

__4.75 36.67 4.75 44.39 4.75 56.33 Table 8 Minimum Qualifying Burnup versus Initial Enrichment For Restricted Storage Region 1A Region 1B Region 2A Region 2B Initial Minimum Initial Minimum Initial Minimum Initial Minimum Enrichment Bumup Enrichment Bumup Enrichment Bumup Enrichment Bumup (w/o U-235)) (GWD/MTU) (w/o U-235)) (GWD/MThJ) (w/o U-235)) (GWD/MTU) (w/o U-235)) (GWD/MTIJ) 4.75 0.00 2.20 0.00 1.80 0.00 1.22 0.00 2.50 3.91 2.00 3.70 2.00 17.55 3.00 9.65 2.50 10.30 2.50 24.73 3.50 15.04 3.00 16.10 3.00 31.31 4.00 19.87 3.50 21.70 3.50 37.40 4.50 24.68 4.00 27.00 4.00 43.15 4.75 27.01 4.50 32.10 4.50 48.65

__4.75 34.50 4.75 51.33 Table 9 Minimum Qualifying Burnup versus Initial Enrichment For Filler Assemblies Region 1A Region 1B Region 2A Region 2B Initial Minimum Initial Minimum Initial Minimum Initial Minimum Enrichment Burnup Enrichment Burnup Enrichment Burnup Enrichment Burnup (w/o U-235)) (GWD/MTU) (w/o U-235)) (GWD/MTU) (w/o U-235)) (GWD/MTU) (w/o U-235)) (GWD/MTU) 1.76 0.00 1.44 0.00 1.15 0.00 1.08 0.00 2.00 5.12 2.00 12.68 2.00 20.00 2.00 23.14 2.50 13.57 2.50 20.17 2.50 27.80 2.50 30.59 3.00 19.80 3.00 27.03 3.00 34.60 3.00 37.42 3.50 25.85 3.50 33.35 3.50 41.10 3.50 43.74 4.00 31.50 4.00 39.33 4.00 47.20 4.00 49.72 4.50 36.93 4.50 45.07 4.50 53.10 4.50 55.49 4.75 39.54 4.75 47.89 4.75 55.90 4.75 58.33

Attachment 6 Page 34 of 44 Table 10 Summary of IFBA Credit Requirements Number of Maximum Fresh Fuel IFBA Rods Enrichment For Unrestricted Storage 0 3.78 16 4.22 32 4.56 48 4.89

Attachment 6 Page 35 of 44 Table 11 Summary of Boron Credit Requirements Unrestricted Restricted w/ Filler 1A 1B 2A 2B 1A 1B 2A 2B k-eff < 0.95 Boron required for k-eff < 0.95 310 160 290 160 330 160 290 160 Reactivity Equivalencing Boron required for bu unc 20 50 120 120 30 50 130 120 Boron required for measured burnup 20 40 120 100 10 40 110 100 Boron required for axial burnup 0 70 310 350 70 90 320 350 Boron required for IFBA manuf unc 20 0 0 0 0 0 0 0 Boron required for IFBA calc unc 70 0 0 0 0 0 0 0 Accident conditions Boron required for misload 300 360 580 740 300 360 580 740 Boron required for abnormal heat load 0 20 0 0 0 20 0 0 Boron required for emergency makeup 10 0 10 0 10 0 10 0 Boron required for single assy in water 170 170 170 170 170 170 170 170 Total Boron Credit Required w/o Accidents 440 320 840 730 440 340 850 730 Total Boron Credit Required with Accidents 740 680 1420 1470 740 700 1430 1470

Attachment 6 Page 36 of 44 Figure 1 McGuire Fuel Pool Layout with Region 1 Detail REGION 1 REGION 2 REGION 1 CELL LAYOUT

Attachment 6 Page 37 of 44 Figure 2 McGuire Fuel Pool Layout with Region 2 Detail REGION 1 REGION 2 1 5 I I 9.1251 TYP.

I

Attachment 6 Page 38 of 44 Figure 3 3 out of 4 Restricted Storage Pattern for Region 1A 0000 0000j l 0000ElID E D0]l LI0 Fuel D Restricted Fuel Filler E Fuel Storage Cell

Attachment 6 Page 39 of 44 Figure 4 2 out of 4 Restricted Storage Pattern for Regions 1B and 2A 0l 0l 0l 0L 0 0L 0I,0'L 0L D- Restricted Fuel F Filler Fuel n Fuel Storage Cell

Attachment 6 Page 40 of 44 Figure 5 1 out of 4 Restricted Storage Pattern for Region 2B

.. DDD..

D Restricted Fuel Filler Fuel Z Fuel Storage Cell

Attachment 6 Page 41 of 44 Figure 6 2 out of 4 Checkerboard Storage Pattern for Regions 1B and 2A DOD 11 DODD JElI DODDElE~

DODD II'

Attachment 6 Page 42 of 44 Figure 7 1 out of 4 Checkerboard Storage Pattern for Region 2B DDDDl DDLID  ::

DDZJD[:1

Attachment 6 Page 43 of 44 Figure 8 McGuire Region 1A and 1B Burnup versus Enrichment Limits 60.000 50.000 40.000 I-1 Filler 1A

- A Unrestricted

• 30.000 --- lB 1 Unrestricted

- 1-B Restricted

2. - -lB 1- Filler 20.000 10.000 0.000 1.00 1.50 2.00 2.50 3.00 3.50 4.00 4.50 Enrichment (w/o U-235)

Attachment 6 Page 44 of 44 Figure 9 McGuire Region 2A and 2B Burnup versus Enrichment Limits 70 60 50 I

2A Unrestricted M 40 e 2A Restricted

--- 2A Filler Sao

- - 2B Unrestricted

- - 2B Restricted E 30

- --.2B Filler 20 10 0 -4 1.00 1.50 2.00 2.50 3.00 3.50 4.00 4.50 Enrichment (wlo U-235)

ATTACHMENT 7 MCGUIRE NUCLEAR STATION BORAFLEX DEGRADATION MANAGEMENT

Attachment 7 Page 1 of 16 MCGUIRE BORAFLEX DEGRADATION MANAGEMENT Table of Contents Section Page

1.0 BACKGROUND

2 2.0 PURPOSE 3 3.0 APPROACH 3 3.1 In-situ Measurement (BADGER) 3 3.2 Computer Modeling (RACKLIFE) 5 4.0 BADGER MEASUREMENTS 8 5.0 RACKLIFE ASSESSMENT 11 6.0 LONG TERM SOLUTION 15

7.0 CONCLUSION

S 15

8.0 REFERENCES

15

Attachment 7 Page 2 of 16

1.0 BACKGROUND

A primary function of the spent fuel storage racks is to provide for safe storage of fuel assemblies in a borated water pool while preventing criticality. Criticality control is provided through the geometrical spacing of the fuel assemblies, use of a neutron poison material (Boraflex), and credit for soluble boron in the spent fuel pool water. Therefore, verification of the poison material composition and dimensions are important to maintaining the sub-critical margin to safety.

The Unit 1 racks were installed in January 1986, and the Unit 2 racks were installed in December 1984. Boraflex, as manufactured, is a silicon rubber material that retains a powder of boron carbide neutron absorbing material. Fixed Boraflex neutron absorbing panels surround each storage cell on all four sides (except for peripheral locations.) The as-built Boraflex panels have a guaranteed minimum 1°B areal density of 0.02 g/cm2 in Region 1 and 0.006 g/cm2 in Region 2. The Boraflex panels are enclosed in a formed stainless steel wrapper sheet which is spot welded to the storage tube. The wrapper sheet is bent at each end to complete the enclosure of the Boraflex panel. The Boraflex is contained in the plenum area between the storage tube and the wrapper plate.

Since the wrapper plate enclosure is not airtight, spent fuel pool water fills the volume of the plenum not taken by the Boraflex panel. It has been observed that after the Boraflex receives a high gamma dose from the spent fuel (>1010 rads), the Boraflex can begin to degrade and dissolve in the wet environment. Thus, the poison material can be slowly removed as it is carried away from the plenum region by the spent fuel pool water, thereby reducing the poison worth of the Boraflex sheets.

The Boraflex degradation phenomenon is documented in NRC Generic Letter 96-04, "Boraflex Degradation in Spent Fuel Pool Storage Racks" (Reference 6.1). Duke Energy responded by letters dated October 22, 1996; December 22, 1997; and December 31, 1998 (References 6.2 through 6.4). In these letters, Duke Energy, in addition to providing background information, committed to l)performing a RACKLIFE assessment of the spent fuel pools, 2)demonstration of the EPRI Boron Areal Density Gage (BADGER) in situ measurement, and 3)assessment of the storage rack reactivity. In the letter to the NRC dated December 31, 1998, Duke Energy committed to submitting a Technical Specification Change Request for McGuire in 1999 to define new spent fuel assembly storage limitations which utilize credit for soluble boron. As part of this request, Duke Energy committed to performing in-situ measurements at a frequency of three years, starting in 2000, to confirm the Boraflex levels assumed in the revised criticality analysis. This License Amendment Request was approved by the NRC on November 27, 2000.

Attachment 7 Page 3 of 16 2.0 PURPOSE Key parameters used as input into the criticality analysis for the spent fuel storage racks (Attachment 6) are the Boraflex properties, including material composition and physical dimensions. The degradation mechanisms of Boraflex, including the gap formation, axial and width shrinkage of Boraflex induced by gamma irradiation, are accounted for in the criticality analysis as uncertainties. Uniform panel dissolution is accounted for in the Boraflex boron-10 (20 B) areal density, with panel designation provided in Selected Licensee Commitments 16.9.24 (Attachment 8). This attachment provides an assessment of the Boraflex in the McGuire spent fuel racks and the methodology for management of the degradation.

3.0 APPROACH Duke Energy's preferred method to verify the amount of remaining 10B areal density is through in-situ measurement, however, it is not feasible to measure each of the more than 3,000 Boraflex panels in each pool. Therefore, the results from in-situ measurements are used in conjunction with a computer program that predicts individual panel degradation. Currently the method of in-situ measurement of the panel average 1°B areal density is through BADGER measurements, and the computer program used to predict individual panel average degradation is RACKLIFE.

3.1 In-Situ Measurement (BADGER)

Northeast Technology Corporation (NETCO), under contract to the Electric Power Research Institute (EPRI), has developed the Boron-10 Areal Density Gage for Evaluating Racks (BADGER). This system is used to measure the 1°B areal density (expressed as grams of 10B per cm2 ) in spent fuel storage racks.

The BADGER system consists of a source head containing a 2 5 2Cf source and a detector head containing BF-3 detectors that are lowered simultaneously into adjacent spent fuel storage cells. A stepper motor and winch attached to the fuel bridge auxiliary hoist allow the detector/source heads to be remotely located at desired elevations in the storage racks. The detector signals are fed into four pre-amplifiers and then to an electronics console that is positioned beside the pool. The signals are recorded on a computer that also controls the stepper motor for positioning of the detector/source heads.

The principle of BADGER is based on the measurement of thermal neutron attenuation by the Boraflex panel(s) between the source and detectors. The number of neutrons emitted by the 2 5 2Cf source that reach the BF-3 detectors, is a function of the 10B areal density in the Boraflex. The magnitudes of the detector signals,

Attachment 7 Page 4 of 16 in turn, are a function of the 1°B areal density in the Boraflex panels. For panels with high density, the detector signals are low, whereas for low areal densities the signals are high.

The BADGER equipment is calibrated by means of a calibration cell that is similar in construction to the spent fuel storage cells and has two sides that represent both Region 1 (flux trap) and Region 2 (egg crate) racks. Each side has a sequence of Boraflex standards of varying known 10B areal densities arranged axially, as well as some gaps of known size. At the beginning of a campaign, the BADGER probe is lowered into the calibration cell and both sides are scanned. The bottom of the calibration cell establishes a reference elevation datum during calibration.

After scanning the calibration cell, BADGER is ready for measurement operations. No further calibration is required during the campaign unless excessive drift in the electronics was to occur.

The areal density of a Boraflex panel is determined by comparing the detector count rate through the panel to the count rates through panels of known areal density in the calibration cell.

In a Boraflex panel that has thinned due to dissolution of the residual Boraflex matrix, a higher detector count rate is recorded. The amount of thinning of a panel in a thinned condition is determined by comparison with a fit of the standards in the calibration cell. To quantify the actual areal density of an irradiated panel in the racks that has undergone some dissolution, usually a relatively intact (e.g., unirradiated or low dose) panel in the racks of known areal density must be available to measure and compare against. This is to account for small but discernable differences between the calibration cell and the actual racks.

A Boraflex panel is measured in the following sequence. The probe is placed into two specific cells on either side of the Boraflex panel of interest and lowered to the bottom of the cell.

A load sensor on the lift assembly provides indication of when the probe is fully inserted. The reference elevation datum is established at the bottom of the cell and all measurements of probe elevation are relative to this datum. (When analyzing the data the elevation is subsequently adjusted to be relative to the bottom of the Boraflex panel according to as-built manufacturing drawings.)

The entire panel is scanned with the heads being moved in two inch increments from the bottom of the cell to the top. The active portion of the detectors is two inches so a scan measurement represents complete axial coverage of the panel. At each elevation, the counts of each detector are measured for a period depending on the source strength, and are recorded by the data-logging computer. As the scan proceeds, the measurement equipment operator monitors the CRT of the computer as the counts

Attachment 7 Page 5 of 16 are plotted on the screen as a function of axial elevation. The operator monitors the elevation where elevated count rates could be indicative of low 10B areal densities or gaps in the Boraflex panel. After the scan is completed, the BADGER heads are moved so that they are flush with the top of the cell. Measuring the BADGER elevation here provides and additional datum to measure elevation in the cell. After the elevation measurement is complete, the probes are moved out of the measured cells and to a new location for subsequent measurement. Measurements are performed at least every three years and may be more frequent based upon engineering judgment.

Panels selected for measurement are based upon RACKLIFE predictions of gamma dose absorption and the resulting Boraflex degradation. A total of 15 panels are typically chosen for each region of each pool. These panels cover the range from zero absorbed dose and zero degradation to the maximum absorbed dose and maximum degradation. Panels that exhibit the least degradation and the most degradation are always selected for measurement, and panels with the least absorbed gamma dose and most absorbed gamma dose are usually selected for measurement. A reason for not selecting these panels would be due to distance from other selected panels that would require a significant number of fuel moves. The remaining panels are selected with consideration of location in relation to other selected panels and the amount of Boraflex degradation. Panels are selected to cover the entire range of degradation with a slight preference of highly degraded panels.

After a measurement campaign, the data are interpreted to provide estimates of Boraflex degradation. Raw counts of individual panels are compared with the counts for the calibration cell with known areal density, counts from the low dose panel, and counts at the top of the cell. Analysis of this data results in a determination of the panel average areal density. This is then compared with the known as-built areal density to determine the measured panel average loss and is stated as a percentage.

Comparison of the measured panel average loss is made with the corresponding designation in SLC 16.9.24 to ensure compliance and with RACKLIFE predictions to ensure validity of these predictions.

3.2 Computer Modeling (RACKLIFE)

RACKLIFE is a computer software package developed by NETCO under contract to EPRI. It is a stand-alone PC/DOS executable program that computes the loss of boron carbide from Boraflex panels in fuel storage racks.

The RACKLIFE code is based on the following principles verified through extensive laboratory testing of irradiated Boraflex specimens as discussed in Reference 6.3:

Attachment 7 Page 6 of 16

a. Boraflex is manufactured as a polydimethyl siloxane (silicon rubber) containing a powder of boron carbide, and a filler material of crystalline silica.

b. As Boraflex ages in the spent fuel pool environment, the polymer matrix is gradually broken down and converted into amorphous silica. This is a function of gamma radiation and exposure to the pool water.

c. Amorphous silica is somewhat soluble in the spent fuel pool water at increasing rates with absorbed gamma dose, pool temperature, and time. This solubilization is the physical mechanism that leads to removal of silica and boron carbide from the storage racks.

d. The amorphous silica and boron carbide from the Boraflex panels is transported into the spent fuel pool in a constant proportion. While the boron released from the spent fuel racks is indistinguishable from the boron in the boric acid added to PWR pools for criticality control (normally greater than 2000 ppm), silica concentrations in the pool are attributable almost exclusively to the Boraflex since it is the only significant source of silica. Thus, the amount of boron carbide that is lost from the Boraflex can be calculated from the silica levels, since the ratio of boron carbide to silica leaving the Boraflex is constant.

e. Boraflex degradation and the resultant silica concentration in the spent fuel pool water is a function of rack design, temperature, and operation of the pool clean-up system.

RACKLIFE performs a mass balance of Si0 2 in the pool and within the wrapper plate plenum that encapsulates the Boraflex panels.

A simple explanation of the mass balance is that the total SiO2 released by the Boraflex panels, in aggregate, is affected by the amount of Si0 2 in solution in the pool water and the amount removed over time by the clean-up system. The contribution of each panel to the bulk SiO2 quantity is determined, based on the irradiation-time history of the panel. All other factors being equal, panels with higher gamma exposures have higher Si02 releases, and for those with equal gamma exposures, the ones that received the dose early in life have higher SiO2 releases.

Having calculated the Si0 2 released by each panel, RACKLIFE then calculates the boron carbide released, based on the fixed ratio of boron carbide to SiC2.

Input parameters generally fall into the categories of pool and rack design; reactor and assembly characteristics; and pool and fuel movement history. Parameters such as the 10B areal density,

Attachment 7 Page 7 of 16 rack dimensions, number of cells and panels, reactor thermal power, assembly type, enrichment, burnup, pool water cleanup operation, silica concentration, temperature, pH, and location of fuel assemblies are all known and input based upon records maintained by the utility. The user controls the input of three main variables; source term model, clean-up system efficiency, and escape coefficients. Two source term models are available, however, the LWRDose model is selected since it typically results in higher absorbed gamma dose by the Boraflex panels. Clean-up system efficiency for the removal of silica may vary from 0% to 1% depending on the type of system that is used. It should be noted that a higher efficiency will result in a larger predicted loss of 10B since the bulk silica concentration will be further from the saturation limit. The escape coefficient used in RACKLIFE is defined as the rate of fluid flow from the panel cavity to the bulk pool in liters/day per volume of fluid in the panel cavity in liters. It is empirically determined by comparing RACKLIFE predictions to BADGER measurements and silica concentration measurements.

The escape coefficients assumed for the McGuire Unit 1 and 2 RACKLIFE models are varied to obtain agreement with both the measured silica concentrations and BADGER results. This is performed for the purpose of benchmarking the RACKLIFE predictions to the BADGER measurements. A constant escape coefficient over time is assumed and it is assumed that the Region 1 and Region 2 escape coefficients are independent of one another. Since, in theory, the escape coefficients should be identical for Unit 1 and Unit 2 due to design similarities, it is assumed that the escape coefficients are identical for the corresponding region of each unit. The following paragraphs describe the statistical approach used to 'normalize' the RACKLIFE code to measured values determined by BADGER.

First, the Region 1 and Region 2 escape coefficients are varied until the RACKLIFE results are brought into good agreement with the BADGER results. The next step is to calculate the difference between the RACKLIFE Boraflex loss values and the BADGER Boraflex loss values. Note that these percentage values cannot be compared directly, since they are based on different as-built values. RACKLIFE assumes the same as-built density in every panel. This density is derived from the nominal Boraflex thickness which is an input to the code, and certain default values (Boraflex density, percent B4 C in Boraflex, percent B in B4 C, and percent 1°B in B) which it applies to every panel in each of the two regions. On the other hand, BADGER bases its loss percentages on panel-specific as-built densities, which are determined from the specific certified material test reports applicable to each of the measured panels. To account for this inconsistency in the percentage loss bases, the percentage losses are converted to absolute losses in g/cm2, and then the arithmetic differences are calculated.

Attachment 7 Page 8 of 16 Next, the arithmetic differences between RACKLIFE and BADGER losses (absolute losses in g/cm2 ) are determined. A 95/95 one sided tolerance limit for the differences is calculated in the following manner:

a) The average and standard deviation of the differences are calculated.

b) The appropriate 95/95 uncertainty is computed by the product of the standard deviation of the sample and the appropriate one-sided 95/95 K-factor for the sample size. This value is then divided by the square root of the number of panels surrounding the fuel assembly - 4 for Region 1, and 2 for Region 2. This latter operation is an appropriate reduction of the uncertainty, based on the propagation of error formula, which recognizes the greater unlikeliness of an assembly being completely surrounded by worst case panels than for having only one worst case panel.

c) The average difference and tolerance interval, which are now in terms of g/cm 2 , are then converted back to a percentage 2

based on the as-built values used by RACKLIFE (0.025 g/cm for Region 1 and 0.0103 g/cm2 for Region 2.)

d) Since the predictions by RACKLIFE are of Boraflex degradation, a correction factor is determined by subtracting the bias and adding the uncertainty.

e) Further iteration is performed on the escape coefficients to produce a correction factor that is slightly negative or very close to zero.

RACKLIFE predictions are performed for semi-annual intervals and used to support the designation of cell sub-region status in SLC 16.9.24. These are updated on a periodic basis when additional BADGER measurements are available to allow benchmarking to more recent data. Predictions include a margin of conservatism that is included by increasing the percentage of minimum remaining 10B areal density by 10% when comparing RACKLIFE predictions to the limits in SLC 16.9.24. (e.g., a RACKLIFE prediction for Region IA must show degradation less than 72.5%, not 75%.) Predictions are valid from the date of the previous prediction until the date of the prediction (e.g., a prediction on December 31, 2002 would be implemented in SLC 16.9.24 from July 1, 2002 until December 31, 2002.)

4.0 BADGER MEASUREMENTS As discussed, a BADGER demonstration campaign was performed in January 1997 with 33 McGuire Unit 2 Boraflex panels evaluated (15 Region 1, 18 Region 2). Panels were selected to include those with the greatest gamma exposures. A full campaign which measured Boraflex panels in both Units 1 and 2 was performed in April 2000. A total of 30 panels in each pool were measured (15 Region 1 and 15 Region 2). Measurements in Unit 2 were performed on the same panels that were measured in January 1997. The

Attachment 7 Page 9 of 16 results, excluding measurement uncertainties, are as follows:

Unit 1 BADGER Region 1 Measurement Boraflex, g/cm2 As-Fab. April 2000 A 4 South 0.0228 0.0231 A 7 East 0.0245 0.0172 B 2 East 0.0240 0.0157 C 1 South 0.0240 0.0173 D 12 East 0.0245 0.0201 E 13 East 0.0241 0.0188 E 13 North 0.0241 0.0171 E 13 West 0.0241 0.0235 F 13 East 0.0245 0.0271 F 13 North 0.0245 0.0201 F 13 West 0.0245 0.0200 G 13 East 0.0241 0.0187 G 13 West 0.0241 0.0270 G 14 South 0.0241 0.0322 G 15 West 0.0236 0.0239 Unit 1 BADGER Region 2 Measurement Boraflex, g/cm2 As-Fab. April 2000 AA 76 East 0.0094 0.0078 AA 78 East 0.0094 0.0076 AA 78 South 0.0094 0.0070 BB 77 West 0.0097 0.0077 BB 79 East 0.0091 0.0070 BB 79 North 0.0091 0.0076 BB 79 West 0.0091 0.0070 CC 76 West 0.0089 0.0075 CC 78 East 0.0092 0.0078 CC 78 South 0.0092 0.0071 DD 79 East 0.0089 0.0075 DD 79 North 0.0089 0.0070 DD 79 West 0.0089 0.0071 KK 4 South 0.0085 0.0082 KK 4 West 0.0085 0.0075

Attachment 7 Page 10 of 16 Unit 2 BADGER Region 1 Measurement Boraflex, g/cm2 As-Fab. January April 1997 2000 A 23 South 0.0216 0.0216 0.0168 C 13 East 0.0240 0.0200 0.0203 C 13 North 0.0240 0.0176 0.0164 D 13 East 0.0240 0.0177 0.0166 E 2 West 0.0242 0.0219 0.0168 E 13 East 0.0240 0.0187 0.0185 E 13 North 0.0240 0.0160 0.0151 E 13 West 0.0240 0.0166 0.0154 F 2 East 0.0244 0.0207 0.0221 F 12 West 0.0240 0.0192 0.0179 F 13 East 0.0240 0.0178 0.0164 F 13 North 0.0240 0.0172 0.0156 F 14 East 0.0236 0.0174 0.0166 G 12 East 0.0242 0.0182 0.0143 H 13 West 0.0236 0.0182 0.0135 Unit 2 BADGER Region 2 Measurement Boraflex, g/cm2 As-Fab. January April 1997 2000 BB 78 South 0.0078 0.0078 0.0083 DD 78 South 0.0082 0.0084 0.0097 DD 78 North 0.0082 0.0074 0.0061 DD 78 East 0.0082 0.0069 N/A FF 78 East 0.0094 0.0090 0.0069 FF 78 North 0.0094 0.0080 0.0067 HH 78 North 0.0091 0.0080 0.0064 HH 78 East 0.0091 0.0093 0.0064 KK 3 South 0.0082 0.0082 0.0082 KK 78 South 0.0091 0.0089 0.0106 KK 78 West 0.0091 0.0081 0.0089 KK 78 North 0.0091 0.0091 0.0062 MM 78 East 0.0090 0.0090 0.0067 MM 78 West 0.0090 0.0076 0.0096 MM 78 North 0.0090 0.0087 N/A MM 78 South 0.0090 0.0087 0.0117 PP 78 South 0.0082 0.0080 N/A PP 78 East 0.0082 0.0081 0.0055 Results from the BADGER measurement campaigns shown above were compared against the then current cell designations and shown to be in compliance. Generally, the loss of boron carbide from the panels was relatively uniform. Some limited thinning may be seen on some edges or possibly along gaps and cracks, but are generally not significant.

Attachment 7 Page 11 of 16 While gap measurements are not the primary function of the BADGER measurement equipment, an assessment is made of gaps in the Boraflex panels based on the BADGER measurements performed at McGuire in April 2000. The largest gap in Region 1 is seen to be 1-2/3 inches with the largest cumulative gaps being 3 inches. In Region 2 the largest gap is seen to be 1-1/3 inches with the largest cumulative gaps being 4-2/3 inches. The gaps appeared to be somewhat randomly distributed with no preferential elevation for gap formation. Furthermore, the gap measurements indicate that the observed panel gaps are either not large enough or in concurrent locations to incur a reactivity penalty.

The next BADGER measurement campaign is being scheduled for May 2002. Panels to be measured will be selected based upon projections by RACKLIFE and will include panels that have previously been measured as well as panels which have not been measured previously. As described in Section 3, these results will be used to ensure compliance with SLC 16.9.24 and to update RACKLIFE predictions of future Boraflex conditions.

5.0 RACKLIFE ASSESSMENENT A RACKLIFE model is maintained and periodically updated for the McGuire Units 1 and 2 spent fuel pool storage racks. One of the key RACKLIFE inputs is the escape coefficient assumed for the storage racks. As described in Section 3.2, the approach used for McGuire Units 1 and 2 is to vary the Region 1 and Region 2 escape coefficients to obtain the best match between the RACKLIFE results and the BADGER results for the measured panels. The escape coefficients determined based upon benchmarking to the January 1997 and April 2000 BADGER campaigns are 1.30 for Region 1 and 0.45 for Region 2.

Changes have been observed in the escape coefficients between the benchmarking of RACKLIFE to the first measurement campaign and the second measurement campaign. Previously the escape coefficients that were determined based upon benchmarking to the first BADGER measurements were 1.25 for Region 1 and 0.05 for Region 2.

Due to the complex interrelationship between the escape coefficients and their impact on the Boraflex degradation predictions, conclusions of the impact of an increase in the escape coefficient cannot be directly inferred. Other factors important to note are the bias, uncertainty, and correction factor. Inspection of these parameters shows that the increase in the escape coefficients results in a decrease in the correction factor. This is due to over-prediction of Boraflex degradation by RACKLIFE, even though the corrected results are similar for both sets of escape coefficients. Presented below are the RACKLIFE predictions on January 8, 1997 for both sets of escape coefficients and the corresponding BADGER measurements.

Attachment 7 Page 12 of 16 Unit 2 RACKLIFE Region 1 Prediction BADGER 1.25 / 1.30 /

0.05 0.45 A 23 South 0.00% 1.97 1.55%

C 13 East 16.67% 25.43 27.74%

C 13 North 26.67% 25.59 27.89%

D 13 East 26.25% 22.52 26.41%

E 2 West 9.50% 15.53 19.08%

E 13 East 22.08% 31.93 33.93%

E 13 North 33.33% 32.30 33.92%

E 13 West 30.83% 33.85 35.40%

F 2 East 15.16% 18.32 22.12%

F 12 West 20.00% 30.36 32.65%

F 13 East 25.83% 33.86 35.40%

F 13 North 28.33% 33.36 35.14%

F 14 East 26.27% 33.84 35.39%

G 12 East 24.79% 29.45 31.14%

H 13 West 22.88% 27.02 27.70%

Unit 2 RACKLIFE Region 2 Prediction BADGER 1.25 / 1.30 /

0.05 0.45 BB 78 South 0.00% 13.83 21.62%

DD 78 South -2.44% 13.80 21.67%

DD 78 North 9.76% 13.83 21.75%

DD 78 East 15.85% 13.82 21.64%

FF 78 East 4.26% 13.82 21.84%

FF 78 North 14.89% 13.83 21.87%

HH 78 North 12.09% 13.82 21.72%

HH 78 East -2.20% 13.79 21.71%

KK 3 South 0.00% 13.83 3.51%

KK 78 South 2.20% 13.82 21.65%

KK 78 West 10.99% 13.83 21.73%

KK 78 North 0.00% 13.81 21.76%

MM 78 East 0.00% 13.82 21.85%

MM 78 West 15.56% 13.82 21.65%

MM 78 North 3.33% 13.82 21.88%

MM 78 South 3.33% 12.91 21.44%

PP 78 South 2.44% 13.83 21.15%

PP 78 East 1.22% 13.83 20.83%

To provide flexibility in fuel storage, the criticality analysis subdivides Region 1 and Region 2, as follows:

Region 1A is assumed to have Boraflex degraded 75 % from the original design minimum (25% remaining) and Region lB is assumed

Attachment 7 Page 13 of 16 to have Boraflex degraded 100% (0% remaining).

Region 2A is assumed to have Boraflex degraded 60 % from the original design minimum (40% remaining) and Region 2B is assumed to have Boraflex degraded 100% (0% remaining).

In the Unit 1 spent fuel racks, only the Region 1A and Region 2A designations are assigned. In the Unit 2 spent fuel racks, Region 1A, Region lB and Region 2A designations are assigned.

Cell designations are presented in the following map:

Attachment 7 Page 14 of 16 Region Designation for Individual Cells Valid Through 7/1/03 Unit2 SA 8

C 0 rRogion 1A E

F Regioni1 G

H [DRegon 2A K Regin 2B L

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Regoin 2

}D Go HN I<KK I LL mN pN 5 6 7 8 9 10 11 12 13 14 15 16 17 1190212234252278 933 23 1 34 35 36 37 3M 39 4Q 41 42 43 44 45 46 47 4849 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 7778 79S

<---.........North AA Unit I Region2 NN MM LL KK JJ HH GG

FF LL BAA 1 2 3 4 5 8 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 3W31 32 33 34 35 36 37 38 39 4. 41 42 4Q 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 W061 62 63 64 65 W587 68 69 70 71 72 73 74 75 76 77 78 79 Region 1 L

H G

r BC A

1 2 J 4 5b 7 /U 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

Attachment 7 Page 15 of 16 6.0 LONG TERM SOLUTION Duke Energy recognizes that long term reliance on partial credit for Boraflex is not a prudent action for maintaining the sub critical safety margin or for effectively managing spent fuel storage. Therefore, Duke Energy has begun to search for alternatives to the reliance on partial credit for Boraflex.

Currently, Duke Energy has placed orders for dry storage systems to accelerate dry storage loading at McGuire in response to the decreasing storage capacity due to Boraflex degradation. Duke Energy has also released an RFQ to pursue a hardware solution to the spent fuel pool storage racks. Options to this solution include the replacement of the existing racks with new spent fuel storage racks which use a neutron poison material approved by the US NRC, and/or the insertion of additional neutron poison into the existing racks. Selection of the solution and the contractor to provide these services is expected early in the second quarter of 2002. Based upon projections of fuel inventory and storage capacity (in consideration of Boraflex degradation) a solution for Region 1 of Units 1 and 2 should be installed in 2003.

Installation of the solution for Region 2 of Unit 1 and 2 would be completed by the end of 2005.

7.0 CONCLUSION

S The initial in-situ verification for the McGuire Unit 2 spent fuel racks in January 1997 showed the Boraflex has degraded in both Region 1 and Region 2. Additional in-situ measurements performed in 2000 has shown continued degradation in Unit 2 and has confirmed degradation in Unit 1. In-situ measurements are scheduled to be performed in May 2002, in advance of the 3 year frequency commitment. These measurements will confirm the Boraflex levels assumed in the revised criticality analysis.

RACKLIFE predictions of Boraflex degradation have been in good agreement with BADGER measurements. Predictions of Boraflex degradation into the future provide the basis for the cell designations in SLC 16.9.24 and include an additional margin of 10%.

Duke Energy is also actively pursuing options to address the long term degradation of Boraflex at McGuire. These options include replacement of the storage racks, and insertion of additional neutron poison (rack or fuel assembly inserts).

8.0 REFERENCES

6.1 "Boraflex Degradation in Spent Fuel Pool Storage Racks," NRC Generic Letter 96-04, June 26, 1996.

Attachment 7 Page 16 of 16 6.2 Duke Power Company Letter to US NRC dated October 22, 1996, Response to Generic Letter 96-04.

6.3 Duke Energy Letter to US NRC dated December 31, 1998, Response to Generic Letter 96-04.

6.4 Duke Energy Letter to US NRC dated December 31, 1999, Response to Generic Letter 96-04.

6.5 "BADGER, a Probe for Nondestructive Testing of Residual Boron-10 Absorber Density in Spent-Fuel Storage Racks:

Development and Demonstration, EPRI TR-107335, October 1997".

6.6 "BADGER Test Campaign at McGuire Unit 1," NETCO Report NET 158-01, July 31, 2000.

6.7 "BADGER Test Campaign at McGuire Unit 2," NETCO Report NET 158-02, July 18, 2000.

6.3 "The RACKLIFE Boraflex Rack Life Extension Computer Code:

Theory and Numerics", DRAFT, NETCO, May 1997.

ATTACHMENT 8 MCGUIRE NUCLEAR STATION PROPOSED REVISION TO UFSAR CHAPTER 16, "SELECTED LICENSEE COMMITMENTS"

Soent Fuel Pool Storaae Rack Poison Material 16.9.24 16.9 AUXILIARY SYSTEMS 16.9.24 Spent Fuel Pool Storage Rack Poison Material COMMITMENT a. The Region 1 panel average storage rack poison material Boron 10 areal density shall be greater than or equal to:

0.005 gm B1o/cm 2 for Region 1A 0 gm B10/cm 2 for Region 1 B

b. The Region 2 panel average storage rack poison material Boron 10 areal density shall be greater than or equal to:

0.003-0.0024 gm Bo/cm 2 for Region 2A 0 gm Blo/cm 2 for Region 2B APPLICABILITY When a fuel assembly is stored in a spent fuel rack cell location.

REMEDIAL ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Panel average storage A.1 Perform ITS SR 3.7.14.1 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rack poison material Boron 10 areal density AND not within limits.

Every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter until the affected fuel assembly is moved.

AND A.2.1 Verify that the fuel 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> assembly in the affected location meets the requirements of ITS LCO 3.7.15(b) for Region 1.

OR McGuire Unit 1 and 2 16.9.24-1 Revision

Spent Fuel Pool Storage Rack Poison Material 16.9.24 (continued) REQUIRED ACTION COMPLETION TIME CONDITION A. (continued). A.2.2 Verify that the fuel 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> assembly in the affected location meets the requirements of ITS LCO 3.7.15(d) for Region 2.

OR A.2.3 Initiate actions to move the Immediately affected fuel assembly to an acceptable location.

TESTING REQUIREMENTS TEST FREQUENCY TR 16.9.24.1 Verify that the panel average spent fuel pool storage 3 years rack poison material is within limits.

BASES The McGuire spent fuel storage racks contain Boraflex neutron-absorbing panels that surround each storage cell on all four sides (except for peripheral sides). The function of these Boraflex panels is to ensure that reactivity of the stored fuel assemblies is maintained within required limits. Boraflex, as manufactured, is a silicon rubber material that retains a powder of boron carbide (B4C) neutron absorbing material. The Boraflex panels are enclosed in a formed stainless steel wrapper sheet that is spot-welded to the storage tube. The wrapper sheet is bent at each end to complete the enclosure of the Boraflex panel. The Boraflex panel is contained in the plenum area between the storage tube and the wrapper plate. Since the wrapper plate enclosure is not sealed, spent fuel pool water is free to circulate through the plenum.

It has been observed that after Boraflex receives a high gamma dose from the stored irradiated fuel (>1010 rads) it can begin to degrade and dissolve in the wet environment. The potential degradation mechanisms with respect to boraflex in spent fuel storage racks include:

(1) gamma radiation-induced shrinkage of boraflex and the potential for developing tears or gaps in the material, and McGuire Unit 1 and 2 16.9.24-2 Revision

Spent Fuel Pool Storage Rack Poison Material 16.9.24 (2) gradual long-term boraflex degradation over the intended service life of the racks as a result of gamma irradiation and exposure to the spent fuel pool environment.

Thus, the B4C poison material can be removed, thereby reducing the poison worth of the Boraflex sheets. This phenomenon is documented in NRC Generic Letter 96-04, "Boraflex Degradation in Spent Fuel Pool Storage Racks". To address this degradation, the spent fuel racks have been analyzed taking credit for soluble boron as allowed in WCAP-14416-NP-A, "Westinghouse Spent Fuel Rack Criticality Analysis Methodology," Revision 1, November 1996.

This methodology ensures that the spent fuel rack multiplication factor, kef is less than or equal to 0.95. Codes, methods and techniques used in the McGuire criticality analysis are used to satisfy this keff criterion. The spent fuel storage racks are analyzed to allow storage of fuel assemblies with enrichments up to a maximum of 4.75 weight percent Uranium-235 while maintaining keff <___0.95 including uncertainties, tolerances, bias, and credit for soluble boron.

Soluble boron credit is used to offset uncertainties, tolerances, and off-normal conditions and to provide subcritical margin such that the spent fuel pool keff is maintained less than or equal to 0.95. The soluble boron concentration required to maintain keff less than or equal to 0.95 under normal conditions is 7-30 850 ppm. In addition, sub-criticality of the pool (keff < 1.0) is assured on a 95/95 basis without the presence of the soluble boron in the pool. Credit is taken for reactivity depletion due to fuel burnup and reduced credit for the Boraflex neutron absorber panels.

The limits specified for the panel average storage rack poison material Boron 10 areal density ensures the keff of the spent fuel pool will always remain < 1.00, assuming the pool to be flooded with unborated water. The specified limit of Boron 10 areal density in boraflex preserves the assumptions used in the analyses of the potential criticality accident scenarios.

These limits are the minimum required concentration for fuel assembly storage. The criticality analysis performed shows that the acceptance criteria for criticality is met for the storage of fuel assemblies with soluble boron credit, reduced credit for the Boraflex panels and the storage configurations and enrichment limits Specified by ITS LCO 3.7.15. The storage configuration requirements specified by ITS LCO 3.7.15 establish four regions within the spent fuel pool storage racks. Figure 16.9.24-1 illustrates the four regions for the Unit 1 spent fuel pool and Figure 16.9.24-2 illustrates the four regions for the Unit 2 pool. The limits specified are not applicable if a storage cell location does not contain a fuel assembly.

The REQUIRED ACTIONS associated with this Selected Licensee Commitment (SLC) are designed to ensure that an unplanned criticality event cannot occur as a result of degraded boraflex conditions. REQUIRED ACTION A.1 verifies the Spent Fuel Pool boron concentration to be within Technical Specification 3.7.14 limits. These limits are based on the cycle-specific Core Operating Limits Requirements (COLR) document. The COLR Spent Fuel Pool boron concentration cannot be less than 2675 ppm soluble boron for any specific cycle (note that the initial boron concentration used in the Spent Fuel Pool boron dilution analysis is 2475 ppm soluble boron). If ITS SR 3.7.14.1 indicates boron concentrations less than the acceptable level, the associated REQUIRED ACTIONS are to immediately suspend movement of fuel assemblies in the pool area and to immediately initiate boron additions to raise the boron concentration to acceptable levels. REQUIRED ACTIONS A.2.1 and A.2.2 associated with this SLC determine if the assembly can be qualified for storage in Region 1B or Region 2B. If the assembly cannot be stored in one of these regions, REQUIRED ACTION A.2.3 requires that actions be initiated immediately to move the affected fuel assembly to an acceptable location.

McGuire Unit 1 and 2 16.9.24-3 Revision

Spent Fuel Pool Storage Rack Poison Material 16.9.24 There may be circumstances that will prevent the movement of the affected assembly in a reasonable time period. For example, if the pool is nearly full, there may not be enough spaces available to meet the required storage configurations of ITS LCO 3.7.15. In this case, it is acceptable to continue REQUIRED ACTION A.1 until the affected fuel assembly can be moved to an acceptable location. The daily verification of boron concentration per ITS SR 3.7.14.1 ensures the assumptions used in the associated criticality analyses are maintained. There is a large amount of margin between the COLR boron concentration and the boron concentration needed to maintain subcritical conditions in the Spent Fuel Pool. Daily verifications are considered to be adequate to ensure that no dilution evolution could go undetected for an extended period resulting in boron concentrations less than the minimum amounts necessary for maintaining subcritical conditions.

The testing requirements will verify that the Boron 10 areal density is within acceptable limits.

The preferred method for verifying the Boron 10 areal density would be in-situ testing at least every three years. Testing may be performed more frequently based on engineering judgment, spent fuel pool water chemistry, and modeling projections of boraflex degradation.

McGuire Unit 1 and 2 16.9.24-4 Revision

FIGURE 16.9.24-1 UNIT 1 SPENT FUEL POOL SUB-REGION MAP Region Designation for Individual Cells Valid Through 7/1/03 Region 2 ss RR PP NN NN MM MM LL LL KK KK JJ JJ HH HH GG GG FF FF EE EE DD DD cc B8 BB AA AAA 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 Region 1 CC L

L [*-Region 1A 8c K KJ IE Region 113 H H G G r---IRegion 2A F E M]Region 213 E

D D C C 8 B A

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 16.9.24-5

FIGURE 16.9.24-2 UNIT 2 SPENT FUEL POOL SUB-REGION MAP Region Designation for Individual Cells Valid Through 7/1/03 RegionI A A B B C y D D m* Region 1A E E F F EERegion IB G G H

J H FE Region 2A J

K K Region 2B L L Region 2 I 1 4 4 b b I b 1U1 11 1Z 13 14 1.5 1b It 1 19 ZU 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 16.9.24-6

Spent Fuel Pool Storage Rack Poison Material 16.9.24

REFERENCES:

1. UFSAR, Section 9.1.2.

2. Issuance of Amendments, McGuire Nuclear Station, Units 1 and 2 (TAC NOS. M89744 and M89745), November 6, 1995.

3. Double contingency principle of ANSI N16.1-1975, as specified in the April 14, 1978 NRC letter (Section 1.2) and implied in the proposed revision to Regulatory Guide 1.13 (Section 1.4, Appendix A).

4. UFSAR, Section 15.7.4.

5. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).

6. NRC Generic Letter 96-04: Boraflex Degradation in Spent Fuel Pool Storage Racks, June 26, 1996.

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

8. Issuance of Amendments, McGuire Nuclear Station, Units 1 and 2 (TAC NOS. MA9730 and MA9731), November 27, 2000.

McGuire Unit 1 and 2 16.9.24-7 Revision

ATTACHMENT 9 MCGUIRE NUCLEAR STATION PROPOSED REVISIONS TO TECHNICAL SPECIFICATION BASES

Spent Fuel Pool Boron Concentration B 3.7.14 B 3.7 PLANT SYSTEMS B 3.7.14 Spent Fuel Pool Boron Concentration BASES BACKGROUND In the two region poison fuel storage rack (Refs. 1 and 2) design, the spent fuel pool is divided into two separate and distinct regions.

Region 1, with 286 storage positions, is designed and generally reserved for temporary storage of new or partially irradiated fuel. Region 2, with 1177 storage positions, is designed and generally used for normal, long term storage of permanently discharged fuel that has achieved qualifying burnup levels.

The McGuire spent fuel storage racks contain Boraflex neutron-absorbing panels that surround each storage cell on all four sides (except for peripheral sides). The function of these Boraflex panels is to ensure that the reactivity of the stored fuel assemblies is maintained within required limits. Boraflex, as manufactured, is a silicon rubber material that retains a powder of boron carbide (B4C) neutron absorbing material. The Boraflex panels are enclosed in a formed stainless steel wrapper sheet that is spot-welded to the storage tube. The wrapper sheet is bent at each end to complete the enclosure of the Boraflex panel. The Boraflex panel is contained in the plenum area between the storage tube and the wrapper plate. Since the wrapper plate enclosure is not sealed, spent fuel pool water is free to circulate through the plenum. It has been observed that after Boraflex receives a high gamma dose from the stored irradiated fuel (>1010 rads) it can begin to degrade and dissolve in the wet environment. Thus, the B4C poison material can be removed, thereby reducing the poison worth of the Boraflex sheets. This phenomenon is documented in NRC Generic Letter 96-04, "Boraflex Degradation in Spent Fuel Pool Storage Racks".

To address this degradation, each region of the spent fuel pool has been divided into two sub-regions; with and without credit for Boraflex. For the regions taking credit for Boraflex, a minimum amount of Boraflex was assumed that is less than the original design minimum B10 areal density.

The McGuire spent fuel storage racks have been analyzed taking credit for soluble boron as allowed in Reference 3. The methodology ensures that the spent fuel rack multiplication factor, keff, is less than or equal to 0.95 as recommended in ANSI/ANS-57.2-1983 (Ref. 4) and NRC guidance (Ref. 5). The spent fuel storage racks are analyzed to allow storage of fuel assemblies with enrichments up to a maximum nominal enrichment of 4.75 weight percent Uranium-235 while maintaining keffr McGuire Units 1 and 2 B 3.7.14-1 Revision No.vo/

Spent Fuel Pool Boron Concentration B 3.7.14 BASES BACKGROUND (continued) 0.95 including uncertainties, tolerances, bias, and credit for soluble boron. Soluble boron credit is used to offset uncertainties, tolerances, and off-normal conditions and to provide subcritical margin such that the spent fuel pool keff is maintained less than or equal to 0.95. The soluble boron concentration require.do aintain keff less than or equal to 0.95 under normal conditions iq -850 ,ppm. In addition, sub-criticality of the pool (keff < 1.0) is assured on a 95/95 basis, without the presence of the soluble boron in the pool. The criticality analysis performed shows that the acceptance criteria for criticality is met for the storage of fuel assemblies when credit is taken for reactivity depletion due to fuel burnup, the presence of Integral Fuel Burnable Absorber (IFBA) rods, reduced credit for the Boraflex neutron absorber panels and storage configurations and enrichment limits Specified by LCO 3.7.15.

APPLICABLE Most accident conditions do not result in an increase in reactivity of the SAFETY ANALYSES racks in the spent fuel pool. Examples of these accident conditions are the drop of a fuel assembly on top of a rack, the drop of a fuel assembly between rack modules (rack design precludes this condition), and the drop of a fuel assembly between rack modules and the pool wall.

However, three accidents can be postulated which could result in an increase in reactivity in the spent fuel storage pools. The first is a drop or placement of a fuel assembly into the cask loading area. The second is a significant change in the spent fuel pool water temperature (either the loss of normal cooling to the spent fuel pool water which causes an increase in the pool water temperature or a large makeup to the pool with cold water which causes a decrease in the pool water temperature) and the third is the misloading of a fuel assembly into a location which the restrictions on location, enrichment, burnup and number of IFBA rods is not satisfied.

For an occurrence of these postulated accidents, the double contingency principle discussed in ANSI N-16.1-1975 and the April 1978 NRC letter (Ref. 6) can be applied. This states that one is not required to assume two unlikely, independent, concurrent events to ensure protection against a criticality accident. Thus, for these postulated accident conditions, the pres*pf additional soluble boron in the spent fuel pool water (above theQ720850)pm required to maintain keff less than or equal to 0.95 under normal conditions) can be assumed as a realistic initial condition since not assuming its presence would be a second unlikely event.

Calculations were performed to determine the amount of soluble boron required to offset the highest reactivity increase caused by either of McGuire Units 1 and 2 B 3.7.14-2 Revision No.X9

Spent Fuel Pool Boron Concentration B 3.7.14 BASES APPLICABLE SAFETY ANALYSES (continued) these postulated accidents and to maintain keff less than or equal to 0.95.

It was found that a spent fuel pool boron concentration of 1470 ppm was adequate to mitigate these postulated criticality related accidents and to maintain keff less than or equal to 0.95. Specification 3.7.14 ensures the spent fuel pool contains adequate dissolved boron to compensate for the increased reactivity caused by these postulated accidents.

Specification 4.3.1.1 c. requires that the spent fuel rac less than or equal to 0.95 when flooded with water borated tot 730850 ppm. A spent fuel pool boron dilution analysis was performed which confirmed that sufficient time is available to detect and mitigate a dilution of the spent fuel pool before the 0.95 keff design basis is exceeded. The spent fuel pool boron dilution analysis concluded that an unplanned or inadvertent event which could result in the dilution of the spent fuel pool boron concentration tf 5*ppm is not a credible event.

The concentration of dissolved boron in the spent fuel pool satisfies Criterion 2 of 10 CFR 50.36 (Ref. 5).

LCO The spent fuel pool boron concentration is required to be within the limits specified in the COLR. The specified concentration of dissolved boron in the spent fuel pool preserves the assumptions used in the analyses of the potential criticality accident scenarios as described in Reference 4. This concentration of dissolved boron is the minimum required concentration for fuel assembly storage and movement within the spent fuel pool.

APPLICABILITY This LCO applies whenever fuel assemblies are stored in the spent fuel pool.

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

When the concentration of boron in the fuel storage pool is less than required, immediate action must be taken to preclude the occurrence of an accident or to mitigate the consequences of an accident in progress.

This is most efficiently achieved by immediately suspending the movement of fuel assemblies. The concentration of boron is restored simultaneously with suspending movement of fuel assemblies.

McGuire Units 1 and 2 B 3.7.14-3 Revision No.,X*

Spent Fuel Pool Boron Concentration B 3.7.14 BASES ACTIONS (continued)

If the LCO is not met while moving irradiated fuel assemblies in MODE 5 or 6, LCO 3.0.3 would not be applicable. 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.

SURVEILLANCE SR 3.7.14.1 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 accidents are fully addressed. The 7 day Frequency is appropriate because no major replenishment of pool water is expected to take place over such a short period of time.

REFERENCES 1. UFSAR, Section 9.1.2.

2. suance of Amendments, McGuire Nuclear Station, Units 1 and (TAC NOS. MA9730 and MA9731), November 27, 2000.JssuaRe of-Amendments, M9Gu'Fe NuclearStation, Units 1 and 2 (T-A NOS. M8974 4 and M89745), November 6, 1995.

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

4. American Nuclear Society, "American National Standard Design Requirements for Light Water Reactor Fuel Storage Facilities at Nuclear Power Plants," ANSI/ANS-57.2-1983, October 7,1983.

5. Nuclear Regulatory Commission, Memorandum to Timothy Collins from Laurence Kopp, "Guidance on the Regulatory Requirements for Criticality Analysis of Fuel Storage at Light Water Reactor Power Plants," August 19, 1998.

6. Double contingency principle of ANSI N16.1-1975, as specified in the April 14, 1978 NRC letter (Section 1.2) and implied in the proposed revision to Regulatory Guide 1.13 (Section 1.4, Appendix A).

7. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).

8. UFSAR, Section 15.7.4.

McGuire Units 1 and 2 B 3.7.14-4 Revision No.,X

Spent Fuel Assembly Storage B 3.7.15 B 3.7 PLANT SYSTEMS B 3.7.15 Spent Fuel Assembly Storage BASES BACKGROUND In the two region poison fuel storage rack (Refs. 1 and 2) design, the spent fuel pool is divided into two separate and distinct regions.

Region 1, with 286 storage positions, is designed and generally reserved for temporary storage of new or partially irradiated fuel. Region 2, with 1177 storage positions, is designed and generally used for normal, long term storage of permanently discharged fuel that has achieved qualifying burnup levels.

The McGuire spent fuel storage racks contain Boraflex neutron-absorbing panels that surround each storage cell on all four sides (except for peripheral sides). The function of these Boraflex panels is to ensure that the reactivity of the stored fuel assemblies is maintained within required limits. Boraflex, as manufactured, is a silicon rubber material that retains a powder of boron carbide (B4C) neutron absorbing material. The Boraflex panels are enclosed in a formed stainless steel wrapper sheet that is spot-welded to the storage tube. The wrapper sheet is bent at each end to complete the enclosure of the Boraflex panel. The Boraflex panel is contained in the plenum area between the storage tube and the wrapper plate. Since the wrapper plate enclosure is not sealed, spent fuel pool water is free to circulate through the plenum. It has been observed that after Boraflex receives a high gamma dose from the stored irradiated fuel (>1010 rads) it can begin to degrade and dissolve in the wet environment. Thus, the B4C poison material can be removed, thereby reducing the poison worth of the Boraflex sheets. This phenomenon is documented in NRC Generic Letter 96-04, "Boraflex Degradation in Spent Fuel Pool Storage Racks".

To address this degradation, each region of the spent fuel pool has been divided into two sub-regions; with and without credit for Boraflex. For the regions taking credit for Boraflex, a minimum amount of Boraflex was assumed that is less than the original design minimum B10 areal density.

Two storage configurations are defined for each region; Unrestricted and Restricted storage. Unrestricted storage allows storage in all cells without restriction on the storage configuration. Restricted storage allows storage of higher reactivity fuel when restricted to a certain storage McGuire Units 1 and 2 B 3.7.15-1 Revision No.X~

Spent Fuel Assembly Storage B 3.7.15 BASES BACKGROUND (continued) configuration with lower reactivity fuel. A third loading pattern, Checkerboard storage, was defined for Regions 1B, 2A and 2B.

Checkerboard storage allows storage of the highest reactivity fuel in each region when checkerboarded with empty storage cells.

The McGuire spent fuel storage racks have been analyzed taking credit for soluble boron as allowed in Reference 3. The methodology ensures that the spent fuel rack multiplication factor, keff, is less than or equal to 0.95 as recommended in ANSI/ANS-57.2-1983 (Ref. 4) and NRC guidance (Ref. 5). The spent fuel storage racks are analyzed to allow storage of fuel assemblies with enrichments up to a maximum nominal enrichment of 4.75 weight percent Uranium-235 while maintaining keff <

0.95 including uncertainties, tolerances, bias, and credit for soluble boron. Soluble boron credit is used to offset uncertainties, tolerances, and off-normal conditions and to provide subcritical margin such that the spent fuel pool keff is maintained less than or equal to 0.95. The soluble boron concentration requird-naintain keff less than or equal to 0.95 under normal conditions ist 7-30850 ppm. In addition, sub-criticality of the pool (keff < 1.0) is assured on a 95/95 basis, without the presence of the soluble boron in the pool. The criticality analysis performed shows that the acceptance criteria for criticality is met for the storage of fuel assemblies when credit is taken for reactivity depletion due to fuel burnup, the presence of Integral Fuel Burnable Absorber (IFBA) rods, reduced credit for the Boraflex neutron absorber panels and storage configurations and enrichment limits Specified by LCO 3.7.15.

APPLICABLE Most accident conditions do not result in an increase in reactivity of the SAFETY ANALYSES racks in the spent fuel pool. Examples of these accident conditions are the drop of a fuel assembly on top of a rack, the drop of a fuel assembly between rack modules (rack design precludes this condition), and the drop of a fuel assembly between rack modules and the pool wall.

However, three accidents can be postulated which could result in an increase in reactivity in the spent fuel storage pools. The first is a drop or placement of a fuel assembly into the cask loading area. The second is a significant change in the spent fuel pool water temperature (either the loss of normal cooling to the spent fuel pool water which causes an increase in the pool water temperature or a large makeup to the pool with cold water which causes a decrease in the pool water temperature) and the third is the misloading of a fuel assembly into a location which the restrictions on location, enrichment, burnup and number of IFBA rods is not satisfied.

For an occurrence of these postulated accidents, the double contingency principle discussed in ANSI N-1 6.1-1975 and the April 1978 NRC letter McGuire Units 1 and 2 B 3.7.15-2 Revision No.,9/

Spent Fuel Assembly Storage B 3.7.15 BASES APPLICABLE SAFETY ANALYSES (continued)

(Ref. 6) can be applied. This states that one is not required to assume two unlikely, independent, concurrent events to ensure protection against a criticality accident. Thus, for these postulated accident conditions, the pres, f additional soluble boron in the spent fuel pool water (above th 7-0850ppm required to maintain keff less than or equal to 0.95 under normaconditions) can be assumed as a realistic initial condition since not assuming its presence would be a second unlikely event.

Calculations were performed to determine the amount of soluble boron required to offset the highest reactivity increase caused by either of these postulated accidents and to maintain kef less than or equal to 0.95. It was found that a spent fuel pool boron concentration of 1470 ppm was adequate to mitigate these postulated criticality related accidents and to maintain keff less than or equal to 0.95. Specification 3.7.14 ensures the spent fuel pool contains adequate dissolved boron to compensate for the increased reactivity caused by these postulated accidents.

Specification 4.3.1.1 c. requires that the spent fuel rack e less than or equal to 0.95 when flooded with water borated tot 3850ý ppm. A spent fuel pool boron dilution analysis was performed Which confirmed that sufficient time is available to detect and mitigate a dilution of the spent fuel pool before the 0.95 keff design basis is exceeded. The spent fuel pool boron dilution analysis concluded that an unplanned or inadvertent event whic4-GGUcJ result in the dilution of the spent fuel pool boron concentration t 7-W8501ppm is not a credible event.

The configuration of fuel assemblies in the spent fuel pool satisfies Criterion 2 of 10 CFR 50.36 (Ref. 7).

LCO a The restrictions on the placement of fuel assemblies within the Region 1A of the spent fuel pool, which have a number of IFBA rods greater than or equal to the minimum qualifying number of IFBA rods in Table 3.7.15-1 or accumulated burnup greater than or equal to the minimum qualified burnups in Table 3.7.15-2 in the accompanying LCO, ensures the keff of the spent fuel pool will alwa in < 0.95, assuming the pool to be flooded with water borated t47-30850'ýppm. Fuel assemblies not meeting the criteria of Tables 3.7.15-1 or 3.7.15-2 shall be stored in accordance with Figure 3.7.15-1.

McGuire Units 1 and 2 B 3.7.15-3 Revision NO./g(

Spent Fuel Assembly Storage B 3.7.15 BASES LCO (continued) b The restrictions on the placement of fuel assemblies within the Region 1 B of the spent fuel pool, which have accumulated burnup greater than or equal to the minimum qualified burnups in Table 3.7.15-4 in the accompanying LCO, ensures the keff of the spent fuel pool will always

=m 0.95, assuming the pool to be flooded with water borated to ippm. Fuel assemblies not meeting the criteria of Table 3.7.15-4 shall be stored in accordance with either Figure 3.7.15-2 and Table 3.7.15-5 for Restricted storage, or Figure 3.7.15-3 for Checkerboard storage.

c The restrictions on the placement of fuel assemblies within the Region 2A of the spent fuel pool, which have accumulated burnup greater than or equal to the minimum qualified burnups in Table 3.7.15-7 in the accompanying LCO, ensures the keff of the spent fuel pool will always

= 0.95, assuming the pool to be flooded with water borated to

ppm. Fuel assemblies not meeting the criteria of Table 3.7.15-7 shall be stored in accordance with either Figure 3.7.15-4 and Table 3.7.15-8 for Restricted storage, or Figure 3.7.15-5 for Checkerboard storage.

d The restrictions on the placement of fuel assemblies within the Region 2B of the spent fuel pool, which have accumulated burnup greater than or equal to the minimum qualified burnups in Table 3.7.15-10 in the accompanying LCO, ensures the kef of the spent fuel pool will always

, <0.95, assuming the pool to be flooded with water borated to p pm. Fuel assemblies not meeting the criteria of Table 3.7.15-10 shall be stored in accordance with either Figure 3.7.15-6 and Table 3.7.15-11 for Restricted storage, or Figure 3.7.15-7 for Checkerboard storage.

APPLICABILITY This LCO applies whenever any fuel assembly is stored in 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.

McGuire Units 1 and 2 B 3.7.15-4 Revision No.,9'

Spent Fuel Assembly Storage B 3.7.15 BASES When the configuration of fuel assemblies stored in the spent fuel pool is not in accordance with the LCO, the immediate action is to initiate action McGuire Units 1 and 2 B 3.7.15-5 Revision No.,9V

Spent Fuel Assembly Storage B 3.7.15 BASES LCO (continued) to make the necessary fuel assembly movement(s) to bring the configuration into compliance.

If unable to move irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not be applicable. If unable to move irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the action is independent of reactor operation. Therefore, inability to move fuel assemblies is not sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.7.15.1 REQUIREMENTS This SR verifies by administrative means that the fuel assembly is in accordance with the configurations specified in the accompanying LCO.

REFERENCES 1. UFSAR, Section 9.1.2.

2. Issuance of Amendments, McGuire Nuclear Station, Units 1 an

"(TAC NOS. MA9730 and MA9731), November 27, 2000.Issuanee of Amcndments, MGGuire Nue-!ear Station, Uits4 1 and 2 (TAG NOS. M8974 4 and M8974 5), November 6, 1995.

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

4. American Nuclear Society, "American National Standard Design Requirements for Light Water Reactor Fuel Storage Facilities at Nuclear Power Plants," ANSI/ANS-57.2-1983, October 7, 1983.

5. Nuclear Regulatory Commission, Memorandum to Timothy Collins from Laurence Kopp, "Guidance on the Regulatory Requirements for Criticality Analysis of Fuel Storage at Light Water Reactor Power Plants," August 19, 1998.

6. Double contingency principle of ANSI N16.1-1975, as specified in the April 14, 1978 NRC letter (Section 1.2) and implied in the proposed revision to Regulatory Guide 1.13 (Section 1.4, Appendix A).

7. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).

McGuire Units 1 and 2 B 3.7.15-5 Revision No.,,g'

ATTACHMENT 10 REVISED MCGUIRE NUCLEAR STATION TECHNICAL SPECIFICATION BASES

Spent Fuel Pool Boron Concentration B 3.7.14 B 3.7 PLANT SYSTEMS B 3.7.14 Spent Fuel Pool Boron Concentration BASES BACKGROUND In the two region poison fuel storage rack (Refs. 1 and 2) design, the spent fuel pool is divided into two separate and distinct regions.

Region 1, with 286 storage positions, is designed and generally reserved for temporary storage of new or partially irradiated fuel. Region 2, with 1177 storage positions, is designed and generally used for normal, long term storage of permanently discharged fuel that has achieved qualifying burnup levels.

The McGuire spent fuel storage racks contain Boraflex neutron-absorbing panels that surround each storage cell on all four sides (except for peripheral sides). The function of these Boraflex panels is to ensure that the reactivity of the stored fuel assemblies is maintained within required limits. Boraflex, as manufactured, is a silicon rubber material that retains a powder of boron carbide (B4C) neutron absorbing material. The Boraflex panels are enclosed in a formed stainless steel wrapper sheet that is spot-welded to the storage tube. The wrapper sheet is bent at each end to complete the enclosure of the Boraflex panel. The Boraflex panel is contained in the plenum area between the storage tube and the wrapper plate. Since the wrapper plate enclosure is not sealed, spent fuel pool water is free to circulate through the plenum. It has been observed that after Boraflex receives a high gamma dose from the stored irradiated fuel (>1010 rads) it can begin to degrade and dissolve in the wet environment. Thus, the B4C poison material can be removed, thereby reducing the poison worth of the Boraflex sheets. This phenomenon is documented in NRC Generic Letter 96-04, "Boraflex Degradation in Spent Fuel Pool Storage Racks".

To address this degradation, each region of the spent fuel pool has been divided into two sub-regions; with and without credit for Boraflex. For the regions taking credit for Boraflex, a minimum amount of Boraflex was assumed that is less than the original design minimum B10 areal density.

The McGuire spent fuel storage racks have been analyzed taking credit for soluble boron as allowed in Reference 3. The methodology ensures that the spent fuel rack multiplication factor, keff, is less than or equal to 0.95 as recommended in ANSI/ANS-57.2-1983 (Ref. 4) and NRC guidance (Ref. 5). The spent fuel storage racks are analyzed to allow storage of fuel assemblies with enrichments up to a maximum nominal enrichment of 4.75 weight percent Uranium-235 while maintaining keff<

McGuire Units 1 and 2 B 3.7.14-1 Revision No.iX

Spent Fuel Pool Boron Concentration B 3.7.14 BASES BACKGROUND (continued) 0.95 including uncertainties, tolerances, bias, and credit for soluble boron. Soluble boron credit is used to offset uncertainties, tolerances, and off-normal conditions and to provide subcritical margin such that the spent fuel pool keff is maintained less than or equal to 0.95. The soluble boron concentration required to maintain keff less than or equal to 0.95 under normal conditions is 850 ppm. In addition, sub-criticality of the pool (keff < 1.0) is assured on a 95/95 basis, without the presence of the soluble boron in the pool. The criticality analysis performed shows that the acceptance criteria for criticality is met for the storage of fuel assemblies when credit is taken for reactivity depletion due to fuel burnup, the presence of Integral Fuel Burnable Absorber (IFBA) rods, reduced credit for the Boraflex neutron absorber panels and storage configurations and enrichment limits Specified by LCO 3.7.15.

APPLICABLE Most accident conditions do not result in an increase in reactivity of the SAFETY ANALYSES racks in the spent fuel pool. Examples of these accident conditions are the drop of a fuel assembly on top of a rack, the drop of a fuel assembly between rack modules (rack design precludes this condition), and the drop of a fuel assembly between rack modules and the pool wall.

However, three accidents can be postulated which could result in an increase in reactivity in the spent fuel storage pools. The first is a drop or placement of a fuel assembly into the cask loading area. The second is a significant change in the spent fuel pool water temperature (either the loss of normal cooling to the spent fuel pool water which causes an increase in the pool water temperature or a large makeup to the pool with cold water which causes a decrease in the pool water temperature) and the third is the misloading of a fuel assembly into a location which the restrictions on location, enrichment, burnup and number of IFBA rods is not satisfied.

For an occurrence of these postulated accidents, the double contingency principle discussed in ANSI N-16.1-1975 and the April 1978 NRC letter (Ref. 6) can be applied. This states that one is not required to assume two unlikely, independent, concurrent events to ensure protection against a criticality accident. Thus, for these postulated accident conditions, the presence of additional soluble boron in the spent fuel pool water (above the 850 ppm required to maintain kef less than or equal to 0.95 under normal conditions) can be assumed as a realistic initial condition since not assuming its presence would be a second unlikely event.

Calculations were performed to determine the amount of soluble boron required to offset the highest reactivity increase caused by either of McGuire Units 1 and 2 B 3.7.14-2 Revision No.,9'

Spent Fuel Pool Boron Concentration B 3.7.14 BASES APPLICABLE SAFETY ANALYSES (continued) these postulated accidents and to maintain keff less than or equal to 0.95.

It was found that a spent fuel pool boron concentration of 1470 ppm was adequate to mitigate these postulated criticality related accidents and to maintain ke, less than or equal to 0.95. Specification 3.7.14 ensures the spent fuel pool contains adequate dissolved boron to compensate for the increased reactivity caused by these postulated accidents.

Specification 4.3.1.1 c. requires that the spent fuel rack keff be less than or equal to 0.95 when flooded with water borated to 850 ppm. A spent fuel pool boron dilution analysis was performed which confirmed that sufficient time is available to detect and mitigate a dilution of the spent fuel pool before the 0.95 keff design basis is exceeded. The spent fuel pool boron dilution analysis concluded that an unplanned or inadvertent event which could result in the dilution of the spent fuel pool boron concentration to 850 ppm is not a credible event.

The concentration of dissolved boron in the spent fuel pool satisfies Criterion 2 of 10 CFR 50.36 (Ref. 5).

LCO The spent fuel pool boron concentration is required to be within the limits specified in the COLR. The specified concentration of dissolved boron in the spent fuel pool preserves the assumptions used in the analyses of the potential criticality accident scenarios as described in Reference 4. This concentration of dissolved boron is the minimum required concentration for fuel assembly storage and movement within the spent fuel pool.

APPLICABILITY This LCO applies whenever fuel assemblies are stored in the spent fuel pool.

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

When the concentration of boron in the fuel storage pool is less than required, immediate action must be taken to preclude the occurrence of an accident or to mitigate the consequences of an accident in progress.

This is most efficiently achieved by immediately suspending the movement of fuel assemblies. The concentration of boron is restored simultaneously with suspending movement of fuel assemblies.

McGuire Units 1 and 2 B 3.7.14-3 Revision No.,,X

Spent Fuel Pool Boron Concentration B 3.7.14 BASES ACTIONS (continued)

If the LCO is not met while moving irradiated fuel assemblies in MODE 5 or 6, LCO 3.0.3 would not be applicable. If moving irradiated fuel assemblies while in MODE 1, 2, 3, or4, 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.

SURVEILLANCE SR 3.7.14.1 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 accidents are fully addressed. The 7 day Frequency is appropriate because no major replenishment of pool water is expected to take place over such a short period of time.

REFERENCES 1. UFSAR, Section 9.1.2.

2. Issuance of Amendments, McGuire Nuclear Station, Units 1 and 2 (TAC NOS. MA9730 and MA9731), November 27, 2000.

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

4. American Nuclear Society, "American National Standard Design Requirements for Light Water Reactor Fuel Storage Facilities at Nuclear Power Plants," ANSI/ANS-57.2-1983, October 7, 1983.

5. Nuclear Regulatory Commission, Memorandum to Timothy Collins from Laurence Kopp, "Guidance on the Regulatory Requirements for Criticality Analysis of Fuel Storage at Light Water Reactor Power Plants," August 19, 1998.

6. Double contingency principle of ANSI N16.1-1975, as specified in the April 14, 1978 NRC letter (Section 1.2) and implied in the proposed revision to Regulatory Guide 1.13 (Section 1.4, Appendix A).

7. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).

8. UFSAR, Section 15.7.4.

McGuire Units 1 and 2 B 3.7.14-4 Revision No.,d

Spent Fuel Assembly Storage B 3.7.15 BASES B 3.7 PLANT SYSTEMS B 3.7.15 Spent Fuel Assembly Storage BASES BACKGROUND In the two region poison fuel storage rack (Refs. 1 and 2) design, the spent fuel pool is divided into two separate and distinct regions.

Region 1, with 286 storage positions, is designed and generally reserved for temporary storage of new or partially irradiated fuel. Region 2, with 1177 storage positions, is designed and generally used for normal, long term storage of permanently discharged fuel that has achieved qualifying burnup levels.

The McGuire spent fuel storage racks contain Boraflex neutron-absorbing panels that surround each storage cell on all four sides (except for peripheral sides). The function of these Boraflex panels is to ensure that the reactivity of the stored fuel assemblies is maintained within required limits. Boraflex, as manufactured, is a silicon rubber material that retains a powder of boron carbide (B4C) neutron absorbing material. The Boraflex panels are enclosed in a formed stainless steel wrapper sheet that is spot-welded to the storage tube. The wrapper sheet is bent at each end to complete the enclosure of the Boraflex panel. The Boraflex panel is contained in the plenum area between the storage tube and the wrapper plate. Since the wrapper plate enclosure is not sealed, spent fuel pool water is free to circulate through the plenum. It has been observed that after Boraflex receives a high gamma dose from the stored irradiated fuel (>1010 rads) it can begin to degrade and dissolve in the wet environment. Thus, the B4C poison material can be removed, thereby reducing the poison worth of the Boraflex sheets. This phenomenon is documented in NRC Generic Letter 96-04, "Boraflex Degradation in Spent Fuel Pool Storage Racks".

To address this degradation, each region of the spent fuel pool has been divided into two sub-regions; with and without credit for Boraflex. For the regions taking credit for Boraflex, a minimum amount of Boraflex was assumed that is less than the original design minimum B10 areal density.

Two storage configurations are defined for each region; Unrestricted and Restricted storage. Unrestricted storage allows storage in all cells without restriction on the storage configuration. Restricted storage allows storage of higher reactivity fuel when restricted to a certain storage McGuire Units 1 and 2 B 3.7.15-1 Revision No.,9"

Spent Fuel Assembly Storage B 3.7.15 BASES BACKGROUND (continued) configuration with lower reactivity fuel. A third loading pattern, Checkerboard storage, was defined for Regions 1B, 2A and 2B.

Checkerboard storage allows storage of the highest reactivity fuel in each region when checkerboarded with empty storage cells.

The McGuire spent fuel storage racks have been analyzed taking credit for soluble boron as allowed in Reference 3. The methodology ensures that the spent fuel rack multiplication factor, keff, is less than or equal to 0.95 as recommended in ANSI/ANS-57.2-1983 (Ref. 4) and NRC guidance (Ref. 5). The spent fuel storage racks are analyzed to allow storage of fuel assemblies with enrichments up to a maximum nominal enrichment of 4.75 weight percent Uranium-235 while maintaining keff<

0.95 including uncertainties, tolerances, bias, and credit for soluble boron. Soluble boron credit is used to offset uncertainties, tolerances, and off-normal conditions and to provide subcritical margin such that the spent fuel pool ke, is maintained less than or equal to 0.95. The soluble boron concentration required to maintain ken less than or equal to 0.95 under normal conditions is 850 ppm. In addition, sub-criticality of the pool (kerr < 1.0) is assured on a 95/95 basis, without the presence of the soluble boron in the pool. The criticality analysis performed shows that the acceptance criteria for criticality is met for the storage of fuel assemblies when credit is taken for reactivity depletion due to fuel burnup, the presence of Integral Fuel Burnable Absorber (IFBA) rods, reduced credit for the Boraflex neutron absorber panels and storage configurations and enrichment limits Specified by LCO 3.7.15.

APPLICABLE Most accident conditions do not result in an increase in reactivity of the SAFETY ANALYSES racks in the spent fuel pool. Examples of these accident conditions are the drop of a fuel assembly on top of a rack, the drop of a fuel assembly between rack modules (rack design precludes this condition), and the drop of a fuel assembly between rack modules and the pool wall.

However, three accidents can be postulated which could result in an increase in reactivity in the spent fuel storage pools. The first is a drop or placement of a fuel assembly into the cask loading area. The second is a significant change in the spent fuel pool water temperature (either the loss of normal cooling to the spent fuel pool water which causes an increase in the pool water temperature or a large makeup to the pool with cold water which causes a decrease in the pool water temperature) and the third is the misloading of a fuel assembly into a location which the restrictions on location, enrichment, burnup and number of IFBA rods is not satisfied.

For an occurrence of these postulated accidents, the double contingency principle discussed in ANSI N-1 6.1-1975 and the April 1978 NRC letter McGuire Units 1 and 2 B 3.7.15-2 Revision No.,8

Spent Fuel Assembly Storage B 3.7.15 BASES APPLICABLE SAFETY ANALYSES (continued)

(Ref. 6) can be applied. This states that one is not required to assume two unlikely, independent, concurrent events to ensure protection against a criticality accident. Thus, for these postulated accident conditions, the presence of additional soluble boron in the spent fuel pool water (above the 850 ppm required to maintain keff less than or equal to 0.95 under normal conditions) can be assumed as a realistic initial condition since not assuming its presence would be a second unlikely event.

Calculations were performed to determine the amount of soluble boron required to offset the highest reactivity increase caused by either of these postulated accidents and to maintain keff less than or equal to 0.95. It was found that a spent fuel pool boron concentration of 1470 ppm was adequate to mitigate these postulated criticality related accidents and to maintain keff less than or equal to 0.95. Specification 3.7.14 ensures the spent fuel pool contains adequate dissolved boron to compensate for the increased reactivity caused by these postulated accidents.

Specification 4.3.1.1 c. requires that the spent fuel rack keff be less than or equal to 0.95 when flooded with water borated to 850 ppm. A spent fuel pool boron dilution analysis was performed which confirmed that sufficient time is available to detect and mitigate a dilution of the spent fuel pool before the 0.95 keff design basis is exceeded. The spent fuel pool boron dilution analysis concluded that an unplanned or inadvertent event which could result in the dilution of the spent fuel pool boron concentration to 850 ppm is not a credible event.

The configuration of fuel assemblies in the spent fuel pool satisfies Criterion 2 of 10 CFR 50.36 (Ref. 7).

LCO a The restrictions on the placement of fuel assemblies within the Region 1A of the spent fuel pool, which have a number of IFBA rods greater than or equal to the minimum qualifying number of IFBA rods in Table 3.7.15-1 or accumulated burnup greater than or equal to the minimum qualified burnups in Table 3.7.15-2 in the accompanying LCO, ensures the keff of the spent fuel pool will always remain < 0.95, assuming the pool to be flooded with water borated to 850 ppm. Fuel assemblies not meeting the criteria of Tables 3.7.15-1 or 3.7.15-2 shall be stored in accordance with Figure 3.7.15-1.

McGuire Units 1 and 2 B 3.7.15-3 Revision Nox

Spent Fuel Assembly Storage B 3.7.15 BASES LCO (continued) b The restrictions on the placement of fuel assemblies within the Region 1 B of the spent fuel pool, which have accumulated burnup greater than or equal to the minimum qualified burnups in Table 3.7.15-4 in the accompanying LCO, ensures the keff of the spent fuel pool will always remain < 0.95, assuming the pool to be flooded with water borated to 850 ppm. Fuel assemblies not meeting the criteria of Table 3.7.15-4 shall be stored in accordance with either Figure 3.7.15-2 and Table 3.7.15-5 for Restricted storage, or Figure 3.7.15-3 for Checkerboard storage.

c The restrictions on the placement of fuel assemblies within the Region 2A of the spent fuel pool, which have accumulated burnup greater than or equal to the minimum qualified burnups in Table 3.7.15-7 in the accompanying LCO, ensures the keff of the spent fuel pool will always remain < 0.95, assuming the pool to be flooded with water borated to 850 ppm. Fuel assemblies not meeting the criteria of Table 3.7.15-7 shall be stored in accordance with either Figure 3.7.15-4 and Table 3.7.15-8 for Restricted storage, or Figure 3.7.15-5 for Checkerboard storage.

d The restrictions on the placement of fuel assemblies within the Region 2B of the spent fuel pool, which have accumulated burnup greater than or equal to the minimum qualified burnups in Table 3.7.15-10 in the accompanying LCO, ensures the kef of the spent fuel pool will always remain < 0.95, assuming the pool to be flooded with water borated to 850 ppm. Fuel assemblies not meeting the criteria of Table 3.7.15-10 shall be stored in accordance with either Figure 3.7.15-6 and Table 3.7.15-11 for Restricted storage, or Figure 3.7.15-7 for Checkerboard storage.

APPLICABILITY This LCO applies whenever any fuel assembly is stored in 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 the spent fuel pool is not in accordance with the LCO, the immediate action is to initiate action McGuire Units 1 and 2 B 3.7.15-4 Revision No./

Spent Fuel Assembly Storage B 3.7.15 BASES I LCO (continued) to make the necessary fuel assembly movement(s) to bring the configuration into compliance.

If unable to move irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not be applicable. If unable to move irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the action is independent of reactor operation. Therefore, inability to move fuel assemblies is not sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.7.15.1 REQUIREMENTS This SR verifies by administrative means that the fuel assembly is in accordance with the configurations specified in the accompanying LCO.

REFERENCES 1. UFSAR, Section 9.1.2.

2. Issuance of Amendments, McGuire Nuclear Station, Units 1 and 2 (TAC NOS. MA9730 and MA9731), November 27, 2000.

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

4. American Nuclear Society, "American National Standard Design Requirements for Light Water Reactor Fuel Storage Facilities at Nuclear Power Plants," ANSI/ANS-57.2-1983, October 7, 1983.

5. Nuclear Regulatory Commission, Memorandum to Timothy Collins from Laurence Kopp, "Guidance on the Regulatory Requirements for Criticality Analysis of Fuel Storage at Light Water Reactor Power Plants," August 19, 1998.

6. Double contingency principle of ANSI N16.1-1975, as specified in the April 14, 1978 NRC letter (Section 1.2) and implied in the proposed revision to Regulatory Guide 1.13 (Section 1.4, Appendix A).

7. 10 CFR 50.36, Technical Specifications, (c)(2)(ii).

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