ML033560622

Amendment No. 198, Elimination of Neutron Absorption Credit for Boraflex

ML033560622
Person / Time
Site:	Robinson
Issue date:	12/22/2003
From:	Chandu Patel Division of Nuclear Materials Safety III
To:	Moyer J Carolina Power & Light Co
Patel C P, NRR/DLPM, 415-3025
Shared Package
ML033560627	List: ML033560622
References
TAC MB9148
Download: ML033560622 (18)

Text

December 22, 2003 Mr. J. W. Moyer, Vice President Carolina Power & Light Company H. B. Robinson Steam Electric Plant Unit No. 2 3581 West Entrance Road Hartsville, South Carolina 29550

SUBJECT:

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 - ISSUANCE OF AN AMENDMENT RE: ELIMINATION OF NEUTRON ABSORPTION CREDIT FOR BORAFLEX (TAC NO. MB9148)

Dear Mr. Moyer:

The Nuclear Regulatory Commission has issued the enclosed Amendment No. 198 to Facility Operating License No. DPR-23 for the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2). This amendment changes the HBRSEP2 Technical Specifications in response to your request dated May 28, 2003, as supplemented October 8, 2003.

The amendment eliminates the need to credit Boraflex neutron-absorbing material for reactivity control in the spent fuel storage pool. The licensee proposed to take credit for a combination of soluble boron and controlled fuel loading patterns in the spent fuel pool to maintain the required subcriticality margins. The programs for monitoring the condition of the Boraflex and the silica content in the water would also be eliminated.

A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commission's bi-weekly Federal Register notice.

Sincerely,

/RA/

Chandu P. Patel, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-261

Enclosures:

1. Amendment No. 198 to DPR-23

2. Safety Evaluation cc w/enclosures:

See next page

December 22, 2003 Mr. J. W. Moyer, Vice President Carolina Power & Light Company H. B. Robinson Steam Electric Plant Unit No. 2 3581 West Entrance Road Hartsville, South Carolina 29550

SUBJECT:

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 - ISSUANCE OF AN AMENDMENT RE: ELIMINATION OF NEUTRON ABSORPTION CREDIT FOR BORAFLEX (TAC NO. MB9148)

Dear Mr. Moyer:

The Nuclear Regulatory Commission has issued the enclosed Amendment No. 198 to Facility Operating License No. DPR-23 for the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2). This amendment changes the HBRSEP2 Technical Specifications in response to your request dated May 28, 2003, as supplemented October 8, 2003.

The amendment eliminates the need to credit Boraflex neutron-absorbing material for reactivity control in the spent fuel storage pool. The licensee proposed to take credit for a combination of soluble boron and controlled fuel loading patterns in the spent fuel pool to maintain the required subcriticality margins. The programs for monitoring the condition of the Boraflex and the silica content in the water would also be eliminated.

A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commission's bi-weekly Federal Register notice.

Sincerely,

/RA/

Chandu P. Patel, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-261

Enclosures:

1. Amendment No. 198 to DPR-23

2. Safety Evaluation cc w/enclosures:

See next page Distribution: See next page Package: ML033560627 TSPages: ML033580397 Amendment: ML033560622 OFFICE PDII-2/PM PDII-2/LA SRXB PDII-2/SC OGC NAME CPatel EDunnington JUhle AHowe AHodgdon DATE 12/10/03 12/10/03 12/17/03 12/18/03 12/18/03 OFFICIAL RECORD COPY

AMENDMENT NO. 198 TO FACILITY OPERATING LICENSE NO. DPR H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DISTRIBUTION:

PUBLIC PDII-2 Rdg.

OGC G. Hill (2)

S. Peters G. Makar ACRS P. Fredrickson, RII cc: Robinson Service List

CAROLINA POWER & LIGHT COMPANY DOCKET NO. 50-261 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 198 License No. DPR-23

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Carolina Power & Light Company (the licensee), dated May 28, 2003, as supplemented October 8, 2003, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment; and paragraph 3.B. of Facility Operating License No. DPR-23 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 198, are hereby incorporated in the license. Carolina Power &

Light Company shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 30 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Allen G. Howe, Chief, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: December 22, 2003

ATTACHMENT TO LICENSE AMENDMENT NO. 198 FACILITY OPERATING LICENSE NO. DPR-23 DOCKET NO. 50-261 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages 3.7-31 3.7-31 4.0-2 4.0-2

--- 4.0-3

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 198 TO FACILITY OPERATING LICENSE NO. DPR-23 CAROLINA POWER & LIGHT COMPANY H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261

1.0 INTRODUCTION

By letter dated May 28, 2003, as supplemented by letter dated October 8, 2003, the Carolina Power & Light Company (licensee) submitted a request for changes to the H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2), Technical Specifications (TS). The requested changes would eliminate the need to credit Boraflex neutron-absorbing material for reactivity control in the spent fuel storage pool. The licensee proposed to take credit for a combination of soluble boron and controlled fuel-loading patterns in the spent fuel pool (SFP) to maintain the required subcriticality margins. The programs for monitoring the condition of the Boraflex and the silica content in the water would also be eliminated.

Since the early 1990s, the Nuclear Regulatory Commission (NRC) and the nuclear power industry have been aware of degradation problems related to Boraflex panel inserts used in the SFPs for nuclear power plants. In 1996, the NRC published Generic Letter (GL) 96-04, Boraflex Degradation in Spent Fuel Pool Storage Racks. This GL provided information describing the Boraflex degradation mechanism and requested information from all nuclear power plant operating license holders regarding the condition of the Boraflex in their SFPs.

Licensees were requested to provide a statement of the ability to maintain a 5-percent subcriticality margin in unborated water. Licensees were further requested to provide a description of any proposed actions to monitor or confirm that the criticality margin could be maintained for the lifetime of the storage racks and to describe any corrective actions to be taken if it could not be maintained.

Since the issuance of GL 96-04, most plants have developed other means of ensuring subcriticality in the SFP, such as alternative neutron-absorbing rack inserts, restrictive rack storage configurations, and soluble boron credits. To eliminate its dependence on Boraflex panel inserts at HBRSEP2, the licensee proposed changes to TS 3.7.13, Fuel Storage Pool Boron Concentration, and TS 4.3, Fuel Storage.

The October 8, 2003, letter provided clarifying information only and did not change the initial proposed no significant hazards consideration determination.

2.0 REGULATORY EVALUATION

2.1 Regulatory Requirements and Review Documents Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix A, General Design Criteria (GDC) for Nuclear Power Plants, provides a list of the minimum design requirements for nuclear power plants. According to GDC 62, Prevention of criticality in fuel storage and handling, the licensee must limit the potential for criticality in the fuel handling and storage system by physical systems or processes. The NRC staff reviewed the amendment request to ensure that the licensee complied with GDC 62.

10 CFR Section 50.68, Criticality accident requirements, provides the NRC regulatory requirements for maintaining subcritical conditions in SFPs. Since the licensee currently uses 10 CFR 50.68 as the licensing basis for its SFP, the NRC staff has reviewed the proposed changes against the appropriate parts of the section. The acceptance criteria for prevention of criticality in the SFP are the following:

1. the effective multiplication factor (keff) shall be less than 1.0 if fully flooded with unborated water, which includes an allowance for uncertainties at a 95-percent probability, 95-percent 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 NRC defined acceptable methodologies for performing SFP criticality analyses in three documents:

1. NUREG-0800, Standard Review Plan, Section 9.1.2, Spent Fuel Storage, Draft Revision 4 (Ref. 3);

2. Proposed Revision 2 to Regulatory Guide 1.13, Spent Fuel Storage Facility Design Basis (Ref. 4); and

3. Memorandum from L. Kopp (NRC) to T. Collins (NRC), Guidance on the Regulatory Requirements for Criticality Analysis of Fuel Storage at Light-Water Reactor Power Plants (Ref. 5).

The NRC staff used the guidance contained in these documents for reviewing this amendment request.

2.2 Description of Proposed TS Changes The licensee provided a descriptive list of the requested changes to the HBRSEP2 TS. The following is the list of the proposed changes:

1. TS 3.7.13, Fuel Storage Pool Boron Concentration: The licensee proposed changing the applicability of the limiting condition for operation (LCO). This LCO required the fuel

storage pool boron concentration to be at least 1500 ppm during spent fuel movement activities in the fuel storage pool. In the proposed TS, this requirement would be extended to all times.

2. In TS 3.7.13, the licensee proposed a new action when the fuel storage pool boron concentration is not within limit. The new action, A.2, would require immediate initiation of action to restore the fuel storage pool boron concentration to within the limit.

3. In TS 4.3.1.1, the licensee proposed replacing the limitation on keff being less than or equal to 0.95 when flooded with unborated water with three separate limitations on keff.

For the low density racks, the limitation would remain the same, i.e., keff must be less than or equal to 0.95 when flooded with unborated water. For the high density racks, keff must be less than or equal to 0.95 when flooded with water with a boron concentration of 1500 ppm, and keff must be less than 1.0 when flooded with unborated water.

4. In TS 4.3.1.1, the licensee proposed deleting the burnable poison requirements for specific enrichments of fuel.

The NRC staff reviewed each of these changes against the regulatory criteria described in Section 2.1 of this report and found them acceptable. The basis for the staffs acceptance and a description of the review it performed is provided below.

3.0 TECHNICAL EVALUATION

In determining the acceptability of the licensees request, the NRC staff reviewed three aspects of the licensees analyses: 1) the computer codes employed; 2) the methodology used to calculate the maximum keff; and 3) the storage configurations and limitations proposed. For each part of the review, the NRC staff evaluated whether the licensees analyses and methodologies provided reasonable assurance that adequate safety margins in accordance with NRC regulations were developed and could be maintained in the HBRSEP2 SFP.

3.1 Computer Codes The licensee performed the analysis of the reactivity effects for the HBRSEP2 SFP racks with the MCNP4a code, a continuous energy three-dimensional Monte Carlo code with an explicit modeling of actinide and fission product nuclide concentrations. The MCNP4a code was benchmarked against criticality experiments under conditions that bound the range of variables in the rack designs. The critical benchmark experiments considered the effects of varying fuel enrichment, boron-10 loading, lattice spacing, fuel pellet diameter, and soluble boron concentration. The experimental data are sufficiently diverse to establish that the method bias and uncertainty will apply to HBRSEP2 storage rack conditions. The licensee determined the MCNP4a code calculation (methodology) bias is 0.0009 with a 95/95 bias uncertainty of

+/- 0.0011.

In addition to using the MCNP4a code to perform the criticality analyses, the licensee employed the CASMO-4 code to perform the fuel depletion analyses, to determine the reactivity effect of the manufacturing tolerances, and to determine the nuclide inventories. Since CASMO-4 is a

two-dimensional multi-group transport theory code, the licensee divided the axes of the spent fuel into segments to calculate the corresponding actinide and fission product inventories. The licensee then used these values to perform the three-dimensional MCNP4a criticality analyses.

The NRC staff reviewed the licensees application of the codes to determine whether each could reasonably calculate the appropriate parameters necessary to support the maximum keff analyses. The NRC staff concludes that the licensees use of the MCNP4a code for calculation of the nominal keff was appropriate since it was benchmarked against experimental data that bound the proposed assembly and rack conditions for the HBRSEP2 SFP. Additionally, the NRC staff finds that the licensees use of the CASMO-4 code was acceptable for determining the delta-k for each manufacturing tolerance and performing the fuel depletion analyses.

3.2 Methodology In accordance with the guidance contained in Refs. 3, 4, and 5, the licensee performed criticality analyses of its SFP. The licensee employed a methodology that combines a worst-case analysis based on the bounding fuel and rack conditions with a sensitivity study using 95/95 analysis techniques. The major components in this analysis were a calculated keff based on the limiting fuel assembly, SFP temperature and code biases, and a statistical sum of 95/95 uncertainties and worst-case delta-k manufacturing tolerances.

In performing its criticality analysis, the licensee determined the keff values using two limiting types of fuel assemblies (highest reactivity) for storage in the SFP. These assemblies are the Advanced Framatome-ANP 15x15 and the Westinghouse 15x15 assemblies. The licensee performed its reactivity analyses for various enrichments, SFP temperatures, manufacturing tolerances, and burnups. In performing these calculations, the licensee assumed appropriately conservative conditions, such as an infinite radial array horizontally and a 30-centimeter water reflector in the axial direction to describe axial neutron leakage, and an SFP temperature corresponding to optimum moderation. The licensee identified the bounding assemblies as the Westinghouse 15x15 for the fresh fuel assembly checkerboard array storage locations and the Advanced Framatome-ANP 15x15 fuel assembly for the unrestricted storage locations. These assemblies served as the nominal assembly for all further calculations the licensee performed in its respective SFP region.

At the NRC staffs request, the licensee provided additional information (Ref. 2) to demonstrate that the licensee chose the limiting fuel assembly types for the SFP and that the limiting types will remain bounding for future core reloads. The licensees original submittal (Ref. 1) indicated that the limiting assembly was identified prior to the consideration of manufacturing tolerance uncertainties. However, this reference also showed that for the Westinghouse and Advanced Framatome fuels, the manufacturing tolerance uncertainty differential is negligible.

Furthermore, in Ref. 2, the licensee stated that its NRC-approved core reload process verifies that future fuel changes remain bounded by the current criticality and accident analyses.

To the calculated keff, the licensee added the methodology bias. As stated in the description of the MCNP4a code, the licensee determined the methodology bias from the critical benchmark experiments. Additionally, when the Boraflex is not credited, the licensee determined that the SFP moderator temperature coefficient of reactivity is positive. Therefore, the licensee added a

reactivity bias corresponding to the maximum allowable normal SFP temperature of 171EF.

Finally, to determine the maximum keff, the licensee performed a statistical combination of the reactivity effects for uncertainties and manufacturing tolerances. The uncertainties included the MCNP bias uncertainty and the MCNP uncertainty. The licensee determined both of these uncertainties to a 95/95 threshold, which is consistent with the requirements of 10 CFR 50.68.

In Ref. 1 and Ref. 2, at the request of the NRC staff, the licensee listed the manufacturing tolerances considered in the reactivity calculations. For each tolerance, the licensee used the CASMO-4 code to calculate a delta-k between the nominal condition and the most limiting tolerance condition. By using the most limiting tolerance condition, the licensee calculated the highest reactivity effect possible. This results in conservative margin since the tolerances will bound the actual parameters. Once the reactivity effects for each of the tolerances were determined, the licensee statistically combined each of the manufacturing tolerances with the 95/95 uncertainties.

The NRC staff reviewed the licensees methodology for calculating the reactivity effects associated with uncertainties and manufacturing tolerances as well as the statistical methods used to combine these values with regards to low-enriched uranium fuel. The NRC staff finds the licensees methods conservative and acceptable. However, in Ref. 1, the licensee included information pertaining to benchmarking the MCNP4a and KENO5a for use with mixed-oxide (MOX) fuel. The NRC staff finds this submittal inadequate to support the use of these codes and methodologies for MOX fuel applications. Therefore, the NRC staff would require further review prior to implementation of these methods for MOX fuel.

3.3 Proposed Storage Configurations As part of the amendment request, the licensee maintained its two storage options, the high-density storage racks and the low-density storage racks. Fuel that meets the minimum burnup requirements as established in Ref. 1, Figures 1-1 and 1-1a, would be allowed to remain in the high-density racks (unrestricted storage). All other fuel, including fresh fuel, would be placed in the low-density racks. The low-density racks are arranged in a checkerboard fashion as described in Ref. 1, with all fuel assemblies separated by an empty cell. Additionally, an empty row separates the low-density and high-density racks in order to limit the interaction of these fuel assemblies and to ensure that the licensees analyses bound all possible fuel configurations.

Since the licensee credits burnup in its SFP criticality analyses for determination of fuel placement, the NRC staff requested the licensee to provide additional information with regards to its methodology for confirming the burnup of the spent fuel. Currently, the licensee calculates fuel assembly burnup for core reloads based on predicted in-core power distributions using its NRC-approved core reload safety analysis process. In Ref. 2, the licensee stated that it updates the burnup information based upon information from the core monitoring system, taking into account the uncertainty in the exposure record. Therefore, the controls used for determining the actual spent fuel assembly burnups are currently in place for determining burnup for existing SFP requirements.

Additionally, the licensee performed analyses for two possible misloading accidents. The first accident involves placing a fresh fuel assembly in the place of a spent fuel location in the

high-density storage area of the SFP. The second accident involves placing a fresh fuel assembly in one of the empty water cell locations of the fresh fuel assembly storage checkerboard array. These conditions provide a conservative estimate of the reactivity effect of the misloading event. The results of the worst-case accident (fresh fuel loaded into an empty cell of a 2x2 checkerboard array) shows that 800 ppm of soluble boron would maintain a maximum keff of 0.938, which is below the regulatory limit of 0.95. The licensees analysis of the misloading of a fresh fuel assembly into a location intended to hold a spent fuel assembly containing a rod cluster control assembly is bounded by the limiting assembly misloading event.

The licensee also performed boron dilution accident analyses to include accidents in which borated water leaks from the SFP and accidents in which unborated water spills into the SFP.

The licensee determined that the limiting accident, a rupture of the fire protection line, would take approximately 3.8 hours0.333 days <br />0.0476 weeks <br />0.011 months <br /> for 302,700 gallons of water to spill onto the auxiliary building floor to dilute to the point where Keff would no longer be below 0.95. Upon a failure of this nature, the licensee determined that the operators in the control room would receive an alarm for the fire protection system header pressure dropping to the auto start setpoint of the fire protection pumps and an alarm for the SFP high-level alarm. The response for both of these alarms is to investigate the cause. The licensee determined that it would not be credible that multiple alarms would fail or be ignored and that the spilling of large volumes of water would not be observed in the auxiliary building. Additionally, given the duration of the event, the licensee determined that there would be sufficient time for corrective action to be taken by the operators.

Because of the multiple alarms and the extended duration of the event, the NRC staff agrees with the licensees assessment.

In addition to the conservative assumptions already described, the licensee included other conservative assumptions in its calculation of the maximum keff values for the SFP. These assumptions include the following: 1) neutron absorption in minor structural members is neglected, 2) any control rods present in a fuel assembly were ignored, and 3) because of a positive temperature coefficient in the absence of Boraflex, SFP temperature is 171oF, any higher would be considered an accident condition. All of these assumptions result in higher predicted fuel reactivities. The NRC staff reviewed each of the assumptions used in the licensees analyses and agrees that each provides for conservative results as well as being consistent with the NRC staffs guidance.

The licensee calculated maximum keff values for the proposed SFP storage locations. In the high-density storage racks, the licensees results show the maximum keff remains less than 0.95 when flooded with borated water of 1500 ppm. In fact, in this configuration, given the minimum burnup requirements, the licensee determined that 200 ppm would be adequate to maintain keff below 0.95. When the high-density racks are flooded with unborated water, the licensees results show that the maximum keff would remain below 1.0. For fresh fuel, on the other hand, enriched to 4.95 +/-0.05 percent, in the low-density storage racks, the analyses show that the maximum keff will remain below 0.95 when flooded with unborated water. For accident condition analysis, the calculations indicate that a soluble boron concentration of 800 ppm is adequate to assure the maximum keff does not exceed 0.95. The HBRSEP2 TS limit on the minimum boron concentration of 1500 ppm provides a conservative margin in meeting the regulatory limit for keff as contained in 10 CFR 50.68 for both storage configurations. The NRC staff reviewed the

licensees criticality analyses of both unborated and borated cases and found that they meet the requirements of 10 CFR 50.68 and GDC 62.

3.4 Monitoring Program The GL 96-04 commitments for HBRSEP2 are described in a letter dated October 23, 1996.

These commitments include evaluating long-term coupons (the final short-term coupon was removed in 1995), monitoring and evaluating SFP silica concentration, and administratively controlling radiation exposure of the Boraflex panels. In the long-term coupon evaluation program, freshly discharged fuel assemblies are moved near the Boraflex coupons approximately every 4 years, and a coupon is removed for analysis. Since Boraflex contains silica as a filler material, the silica content of the pool water indicates the amount of boron carbide dissolved from the Boraflex. The administrative controls involve off-loading fuel from the core into low-density racks without Boraflex, while utilizing high-density racks for storage of new fuel with poison (gadolinia) inserts and high-burnup fuel.

The next Boraflex coupon test is scheduled for the April 2004 refueling outage. Approval of the proposed license amendment would eliminate the coupon testing and silica trending prior to that outage. HBRSEP2 has, in the meantime, established procedural controls to ensure SFP boron concentration is measured every 7 days (+/- 25 percent), with action required if the measured boron concentration is below 1500 ppm.

The proposed amendment does not involve a change in the materials, conditions, or water chemistry in the SFP. Rather, it is a change in the evaluation of existing materials and pool chemistry. The NRC staff therefore expects the proposed changes to have no effect on the chemical or mechanical stability of materials exposed to the pool water.

The amendment would allow the licensee to discontinue the Boraflex and silica monitoring established in response to GL 96-04. Since the proposed criticality analysis methodology does not take credit for Boraflex, the NRC staff concludes that the GL 96-04 commitments would no longer be valid upon approval of the criticality analysis methodology proposed for HBRSEP2.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the State of South Carolina official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (68 FR 40710). Accordingly, the amendment meets the eligibility criteria for categorical

exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The NRC staff reviewed the effects of the proposed changes using the appropriate requirements of 10 CFR 50.68 and GDC 62. The NRC staff found that the licensees amendment request provided reasonable assurance that under both normal and accident conditions the licensee would be able to safely operate the plant and comply with the NRC regulations. Therefore, the NRC staff finds the licensees amendment request acceptable.

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1. Letter from C. T. Baucom, Progress Energy to U.S. Nuclear Regulatory Commission, Request for Technical Specifications Change Regarding Credit for Spent Fuel Storage Pool Dissolved Boron, May 28, 2003, ADAMS Accession No. ML031500343.

2. Letter from J. F. Lucas to U.S. Nuclear Regulatory Commission, Supplement to Amendment Request Regarding Credit for Spent Fuel Storage Pool Dissolved Boron (TAC No. MB9148), October 8, 2003, ADAMS Accession No. ML032880493.

3. NUREG-0800, Standard Review Plan, Section 9.1.2, Spent Fuel Storage, Draft Revision 4, April 1996.

4. Proposed Revision 2 to Regulatory Guide 1.13, Spent Fuel Storage Facility Design Basis, December 1981.

5. NRC Memorandum from L. Kopp to T. Collins, Guidance on the Regulatory Requirements for Criticality Analysis of Fuel Storage at Light-Water Reactor Power Plants, August 19, 1998.

Principal Contributors: S. Peters G. Makar Date: December 22, 2003

Mr. J. W. Moyer H. B. Robinson Steam Electric Plant, Carolina Power & Light Company Unit No. 2 cc:

Steven R. Carr Mr. C. T. Baucom Associate General Counsel - Legal Supervisor, Licensing/Regulatory Programs Department H. B. Robinson Steam Electric Plant, Progress Energy Service Company, LLC Unit No. 2 Post Office Box 1551 Carolina Power & Light Company Raleigh, North Carolina 27602-1551 3581 West Entrance Road Hartsville, South Carolina 29550 Ms. Margaret A. Force Assistant Attorney General Ms. Beverly Hall, Section Chief State of North Carolina N.C. Department of Environment Post Office Box 629 and Natural Resources Raleigh, North Carolina 27602 Division of Radiation Protection 3825 Barrett Dr.

U. S. Nuclear Regulatory Commission Raleigh, North Carolina 27609-7721 Resident Inspectors Office H. B. Robinson Steam Electric Plant Mr. Robert P. Gruber 2112 Old Camden Road Executive Director Hartsville, South Carolina 29550 Public Staff - NCUC 4326 Mail Service Center Mr. T. P. Cleary Raleigh, North Carolina 27699-4326 Plant General Manager H. B. Robinson Steam Electric Plant, Mr. Henry H. Porter, Assistant Director Unit No. 2 South Carolina Department of Health Carolina Power & Light Company Bureau of Land & Waste Management 3581 West Entrance Road 2600 Bull Street Hartsville, South Carolina 29550 Columbia, South Carolina 29201 Mr. Chris L. Burton Mr. James W. Holt Director of Site Operations Manager H. B. Robinson Steam Electric Plant, Performance Evaluation and Unit No. 2 Regulatory Affairs PEB 7 Carolina Power & Light Company Progress Energy 3581 West Entrance Road Post Office Box 1551 Hartsville, South Carolina 29550 Raleigh, North Carolina 27602-1551 Public Service Commission Mr. John H. ONeill, Jr.

State of South Carolina Shaw, Pittman, Potts, & Trowbridge Post Office Drawer 11649 2300 N Street NW.

Columbia, South Carolina 29211 Washington, DC 20037-1128 J. F. Lucas Manager - Support Services - Nuclear H. B. Robinson Steam Electric Plant, Unit No. 2 Carolina Power & Light Company 3581 West Entrance Road Hartsville, South Carolina 29550