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ER-W3-2005-0396-000, Confirmatory Criticality Calculation Correction for Spent Fuel Racks
	ML061280113
Person / Time
Site:	Waterford
Issue date:	09/14/2005
From:	Mcadams V; Entergy Nuclear South
To:	; Office of Nuclear Reactor Regulation
References
	ER-W3-2005-0396-000
	Download: ML061280113 (10)
	v • d • e

Page 1 of 10 I.

OVERVIEW 1 SIGNATURES Facility: Waterford 3 Document Reviewed :

ER-W3-2005-0396-000 Change/Rev. :

RO System Designator(s)/Description : Revise FSAR table 9.1-8 to reflect the changes made in the Holtec Calculation I-961562, Revision 1.

Description of Proposed Activity: CR-WF3-2005-778 documents that during the preparation of Echelon confirmatory criticality calculations for Cycle-14 of Waterford-3, two errors were discovered in Hottec International Report HI-961562, "Criticality Calculation Package for Waterford 3," dated March, 1997. This report was incorporated into the Waterford-3 document control system as Safety Related Calculation ECS98-006. One error was conservative and changes were not made for this error. The other error was non-conservative. This error resulted in an increase in the maximum calculated Kaff of the spent fuel racks increasing from 0.9284 to 0.9318. HOLTEC issued Revision 1 to the calculation on 3115105. ECS98-006 is being revised to incorporate the Revision 1 of the HOLTEC calculation.

The revision to the calculation impacts data contained in FSAR table 9.1-8 and the FSAR Section 9.1 references. This ER makes the necessary changes to the FSAR.

Check the applicable reviews) : (Only the sections indicated must he included in the Review.)

Preparer:

50.59 REVIEW FORM

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Name (print) / Signature f Compares( / Departm OSRC :

Chairman's Nan-k (print arg (Required only for Prograrnnatic, LI-101-01, Rev. 8 ; Effective Date : 6123105 Van McAdams/

4 IEOIJReactor En ineerin 1317105 Name (print) ! Signature 1 Company / Department / Date ee,4 /

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/ Date xclusion Sc enings and 50.59 Evaluations.)

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Sections I, 11, and IV required

Page 2 of 10 11.

SCREENINGS A.

Licensing Basis Document. Review 1.

Does the proposed activity impact the facility or a procedure as described in any of the following Licensing Basis Documents?

' If "YES," see L-1-101. No LBO change is required.

~ If 'YES," notify the responsible department and ensure a 50.54 evaluation is performed. Attach the 50.54 evaluation, s Changes to the Emergency Plan, Fire Protection Program, and Offsite Dose Calculation Manual must be approved by the OSRC in accordance with NMM OM-119.

° If "YES," evaluate the change in accordance with the requirements of the facility's Operating License Condition or under 50.59, as appropriate.

LIA01-01, Rev. 8; Effective Date : 5123105 50.59 REVIEW FORM LBDs controlled under other regulations YES NO CHANGE # (if applicable) and/or SECTIONS IMPACTED Quality Assurance Program Manual 2 Emergency Plan' 3 El 1031 Fire Protection Program' 4 (includes the Fire Hazards Analysis)

Oflsite Dose Calculations Manual3, 4 If "YES," evaluate any changes in accordance with the appropriate regulation AND initiate an L.BD change in accordance with NMM LI-113.

LBDs controlled under 50.59 YES NO CHANGE # (if applicable) and/or SECTIONS IMPACTED FSAR

TS Bases Technical Requirements Manual 1

Core Operating Limits Report

`"

04, NRC Safety Evaluation Report and

[1~1~

supplements for the initial FSAR' NRC Safety Evaluations for 11 z

amendments to the Operating License' If "YES," perform an Exemption Review per Section III OR perform a 50.59 Evaluation per Section IV OR obtain NRC approval prior to implementing the change by initiating an LBD change in accordance with NMM LI-113. If obtaining NRC approval, document the LBD change in Section II.A.5. However, the change cannot be implemented until approved by the NRC. Complete Section II.

Operating License YES NO CHANGE # and/or SECTIONS IMPACTED Operating License TS El N RC Orders Lj If "YES," obtain NRC approval prior to implementing the change by initiating an LBD change in accordance with NMM L.I-113. (See LI-101 for exceptions.)

Rage 3 of 2.

Does the proposed activity involve a test or experiment not described in the FSAR?

Basis If "YES," perform a 50.59 Evaluation per Section IV OR obtain NRC approval prior to implementing the change AND initiate an LBD change in accordance with NMM LI-1'13, if applicable. If obtaining NRC approval, document the change in Section II.A.S. However, the change cannot be implemented until approved by the NRC. Complete Section I1.

Explain why the proposed activity does or does not impact the Operating License/Technical Specifications and/or the FSAR. If the proposed activity involves a potential test or experiment not previously described in the FSAR also include an explanation. Discuss other LBDs if impacted. Adequate basis must be provided within the Screening such that a third-party reviewer can reach the same conclusions. Simply stating that the change does not affect TS or the FSAR is not an acceptable basis.

FSAR A search of the Autonomy 50.59 Search database using the keywords noted below found that this change impacts SER 980111 and FSAR Table 9.1-8. The Evaluation section of the SER states that the criticality calculation for Region 1 resulted in a maximum Keff of 0.9284. Revision 1 of the calculation found the maximum Keff of 0.9318. However, the conclusion of the SER remains valid. FSAR Table 9.1-8 provides tolerances for the spent fuel racks, uncertainties for the calculation and reactivity results that are changed by this revision of the calculation. The reference to the HOLTEC report in FSAR section 9.1 is also impacted.

Operating License/Technical Specifications The search of the Autonomy 50.59 _Search database using the keywords noted below and a manual review of Technical Specification Section 5.6 showed that the operating license and Technical Specifications are not impacted by this change.

Test or Experiment 4.

References Autonomy 50.59-Search U-101-01, Rev. 8 ; Effective Date : 6123105 50.59 REVIEW FORM No This change does not constitute a test or experiment and therefore does not involve a potential test or experiment not previously described in the FSAR Discuss the methodology for performing LBD searches. State the location of relevant licensing document information and explain the scope of the review such as electronic search criteria used (e.g., key words) or the general extent of manual searches. NOTE : Ensure that manual searches are performed using controlled copies of the documents. If you have any questions, contact your site Licensing department.

Electronic search method used :

Keywords : "Spent Fuel" NEAR10 "Critical", "Spent Fuel" NEAR10 Keff, " oltec", "ECS98-0(36"

LBC7s reviewed manually:

FSRR Section 9.1.2, Technical Specifications Section 5,6

5.

Is the validity of this Review dependent on any other change?

© Yes If "YES," list the required changes/submittals. The changes covered by this 50,59 Review cannot be implemented without approval of the other identified changes (e.g., license amendment request). Establish an appropriate notification mechanism to ensure this action is completed, LI-101-01, Rev. 8; Effective Date : 6123105 No

Page 5 of 10 B.

ENVIRONMENTAL SCREENING If any of the following questions is answered "yes," an Environmental Review most be performer! in accordance with NMM Procedure EV-115 and attached to this 50.59 Review. Consider both routine and non-routine (emergency) discharges when answering these questions.

Will the proposed activity being evaluated :

YES NO F-1 Z

3.

4.

5.

6.

Cl 12.

D 12 MNU 1U77QI~ j~*794 Involve a land disturbance equal to or in excess of one acre (i.e., grading activities, construction of buildings, excavations, reforestation, creation or removal of ponds)?

Involve any land disturbance of undisturbed land areas (i.e., grading activities, construction, excavations, reforestation, creating, or removing ponds)?

Increase the concentration or quantity of chemicals being discharged to the river, lake, or air?

Discharge any new or different chemicals that are currently not authorized for use by the state regulatory agency?

7.

8.

9.

F1 Modify the design or operation of the plant that will change the path of an existing water discharge or that will result in a new water discharge?

10.

Involve the installation of stationary fuel burning equipment or use of portable fuel burning equipment (i.e., diesel fuel oil, butane, gasoline, propane, and kerosene)?'

Involve the installation or use of equipment that will result in a new or additional air emission discharge?

13.

14.

15.

involve burial or placement of any solid wastes in the site area that may affect runoff, surface water, or groundwater?

See NMM Procedure EV-117 for guidance in answering this question.

L1-101-01, Rev. 8 ; Effective Date, 6123/05

age 6 of 10 C.

SECURITY PLAN SCREENING If any of the following questions is answered "yes," a Security Plan Review must be performed by the Security Department to determine actual impact to the Plan and the need for a change to the Plan.

Could the proposed activity being evaluated :

50.59 REVIEW F© The Security Department answers the following question if one of questions C.1 through CAfl above was answered "yes."

Is a change to the Security Plan required?

Name of Security Plan reviewer (print / Signature 1 Data LIA01-01, Rev. 8 ; Effective Date : 6123/05 1. 0 Add, delete, modify, or otherwise affect Security department responsibilities (e.g.,

including fire brigade, fire watch, and confined space rescue operations)?

2, Result in a breach to any security barrier(s) (e.g., HVAC ductwork, fences, doors, walls, ceilings, floors, penetrations, and ballistic barriers)?

3. M Cause materials or equipment to be placed or installed within the Security Isolation Zone?

4.

[~

Affect (block, move, or alter) security lighting by adding or deleting lights, structures, buildings, or temporary facilities?

04 Modify or otherwise affect the intrusion detection systems (e.g., E-fields, microwave, fiber optics)?

6.

7.

8.

Modify or otherwise affect primary or secondary power supplies to access control equipment, intrusion detection equipment, other security equipment, or to the Central Alarm Station or the Secondary Alarm Station?

9.

10.

Page 7 of 10 D.

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) SCREENING (NOTE : This section is not applicable to Grand Gulf or Waterford 3 and may be removed from 50.58 Revi performed for Waterford 3 proposed activities.)

If any of the following questions is answered "YES," a 72.48 Review must be performed accordance with NMM Procedure LI-112 and attached to this 50.59 Review.

Will the proposed activity being evaluated :

YES NO 0

2. n 0 3.

El El 9.

0 El Any activity that directly impacts spent fuel cask storage or loadin Involve the ISFSI including the concrete pad, security fence, fighting?

rom the Fuel Building to the ISFSI?

Involve a change to the design or operation of the Fyllvl Building fuel bridge including setpoints and limit switches?

Involve a change to the Fuel Building Involve a change to the Fuel Building water sources, and water chemistry?

Involve a change to the F=uel Buildigg handling equipment (e.g., bridges and cask cranes, structures, load paths, lighting, a 8.

the ISFSI securi y?

ge to off-site radiolo I reIe s prot ion ram non-ISFSI sources?

hange to spent fuel characteristics?

nelchange heavy load pathways?

'volve fire and explosion protection near or in the on-site transport paths or near the Involve a c Involve Re New structures near the ISFSI?

50.59 REVIEW FORM Rooms) radiation monitoring?

ncluding pool levels, cask pool gates, cooling ei Buildiag ventilation ttyt could potentially impact cask loading Involve a change to the loading bay or supporting components power that could potentially impact cask loading or storage activities?

Modifications to any plant systems that support dry fuel storage activities?

Involve a change to the nitrogen supply, service air, demineralized water or borated water system in the Fuel Building?

LI-101-01, Rev. S ; Effective Date : 6123105

Page 8 of 10

III, 50.53 EVALUATION EXEMPTION B.

Basis 50.59 REVIEW FORM A.

Check the applicable box below. 1f a box is checked, clearly document the basis in Section 111.13, below. If none of the boxes are appropriate, perform a 50,59 Evaluation in accordance with Section IV. Provide supporting documentation or references as appropriate.

The proposed activity does not adversely affect the design function of an SSC as descrj the FSAR ; AND The proposed activity does not adversely affect a method of performing or control function of an SSC as described in the FSAR ; AND The proposed activity does not adversely affect a method of evaluation that intended design function(s) of an SSC described in the FSAR will be acco An approved, valid 50.59 Review(s) covering associated aspects of the p exists. Reference 50.59 Evaluation #f (if applicable) or the previous 50.59 Review remains valid.

The NRC has approved the proposed activity or portions thereof.

Reference :

Provide a clear, concise basis for determining the proposed activity may b reach the same conclusions.

LI-101-01, Rev. 8 ; Effective Date : 6123/05 osed activity already i documentation. Verify xempted such that a third-party reviewer can N/A

Page 9 of 10 IV.

50.59 EVALUATION License Amendment Determination Does the proposed Change being evaluated represent a change to a method of evaluation ONLY? If "Yes," questions 1 - 7 are not applicable ; answer only Question 8. If "No," answer all questions below.

Does the proposed Change :

50.59 REVIEW FORM Yes BASIS : The increase in the analyzed Keff of the fuel will maintain the fuel subcritical. This change does not have any impact on the failure mode of the spent fuel racks or any other structures, systems, or components important to safety. Therefore, this change will not increase the consequences of any SSC malfunction.

No 1.

Result in more than a minimal increase in the frequency of occurrence of an accident

[~ Yes previously evaluated in the FSAR?

No BASIS : The accident described in the FSAR is a fuel handling accident. The design function of the spent fuel racks is to maintain the fuel subcritical with a Keff of less than 0.95 assuming the spent fuel is flooded with nonborated water and to maintain a subcritical array of Keff less than 0.95 under all design loadings.

The increase in the maximum Keff from 0.9284 to 0.9318 is a marginal increase that maintains the design basis of the spent fuel racks, i.e., Keff less than 0.95. This change has no impact on the seismic qualification of the spent fuel racks. This change has no impact on any initiators of accidents analyzed in the FSAR and therefore, will not increase the frequency of a fuel handling accident.

2.

Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a

No BASIS : As stated above the function of the spent fuel racks is to maintain the fuel subcritical with a Keff of less than 0.95. An increase in Keff to 0.9318 will maintain the spent fuel more than 5% subcritical as analyzed in and required by the FSAR. Therefore, this change will not increase the likelihood of a criticality event or a fuel handling accident.

3.

Result in more than a minimal increase in the consequences of an accident previously

No BASIS : The marginal increase in total Keff from 0.9284 to 0.9318 will still ensure that the Keff of the fuel will remain below 0.95 and that the fuel will remain subcritical under all conditions and for any fuel handling accidents. The increase in Keff will not impact any of the equipment required to mitigate the consequences of a fuel handling accident. Therefore, this activity will not result in an increase in the consequences of a fuel handling accident.

4.

Result in more than a minimal increase in the consequences of a malfunction of a structure,

No 5.

Create a possibility for an accident of a different type than any previously evaluated in the Yes FSAR?

No BASIS_ The Keff of the spent fuel only has an impact on a fuel handling accident. Since the spent fuel will remain subcritical with a Keff of less than 0.95 this change will not create the possibility of an accident of a different type than previously evaluated.

LI-101-01, Rev. 8 ; Effective Date : 6/23/05

Page 10 of 10 LI-101-01, Rev. 8 ; Effective Date : 6123105 6.

Create a possibility for a malfunction of a structure, system, or component important to safety

No BASIS : Increasing the K¢ff of the spent fuel where the K,,ff remains below 0.95 does not create a new failure mode of the spent fuel racks or any SSC nor does it change the result of the failure of the spent fuel racks or any SSC. The spent fuel will remain more than 5% subcritical under all conditions.

7.

Result in a design basis limit for a fission product barrier as described in the FSAR being exceeded or altered?

Therefore, the only fission product barrier that can be affected by this change is the fuel cladding. Since this change will ensure that the spent fuel will remain more then 5% subcritical this barrier wi61 not be challenged by this change.

8.

Result in a departure from a method of evaluation described in the FSAR used in establishing F1 Yes the design bases or in the safety analyses?

No BASIS : The method of analyzing the subcriticality of the spent fuel has not changed. A change was made in the dimensions of the spent fuel racks entered into the calculation based on the tolerances of the racks to ensure the worst case Karr was calculated. Therefore the method of evaluation has not changed.

If any of the above questions is checked "YES," obtain NRC approval prior to implementing the change by initiating a change to the Operating License in accordance with NMM Procedure LI-113.

ML061280113

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