ML081480471

Improved Technical Specification Conversion License Amendment Request, Volume 15, (Revision 1), Chapter 4.0 - Design Features

ML081480471
Person / Time
Site:	Davis Besse
Issue date:	05/16/2008
From:	FirstEnergy Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation
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Download: ML081480471 (19)

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YwO DAVIS-BESSE NUCLEAR POWER STATION UNIT 1 IMPROVED TECHNICAL SPECIFICATION CONVERSION LICENSE AMENDMENT REQUEST VOLUME 15 (Rev. 1)

CHAPTER 4.0 - DESIGN FEATURES

Attachment 1, Volume 15, Rev. 1, Page i of i Summary of Changes ITS Chapter 4.0 Change Description Affected Pages The changes described in Davis-Besse response to Page 15 Question 200710090851 have been made. This change makes a minor change to a JFD.

Page 1 of I Attachment 1, Volume 15, Rev. 1, Page i of i

Attachment 1, Volume 15, Rev. 1, Page 1 of 17 ATTACHMENT 1 VOLUME 15 DAVIS-BESSE IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS CHAPTER 4.0 DESIGN FEATURES Revision 1 Attachment 1, Volume 15, Rev. 1, Page 1 of 17

Attachment 1, Volume 15, Rev. 1, Page 2 of 17 LIST OF ATTACHMENTS 1.ITS 4.0 Attachment 1, Volume 15, Rev. 1, Page 2 of 17

, Volume 15, Rev. 1, Page 3 of 17 ATTACHMENT 1 ITS 4.0, Design Features , Volume 15, Rev. 1, Page 3 of 17

, Volume 15, Rev. 1, Page 4 of 17 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 15, Rev. 1, Page 4 of 17

Attachment 1, Volume 15, Rev. 1, Page 5 of 17 ITS 4.0 ITS Design Features 5,0 5.0 DESIGN FEATURES 4.1 5.1 Site Location The DavisIBesse Nuclear Power Station, Unit Number 1, site is located on Lake Erie in Ottawa County, Ohio, approximately six miles northeast from Oak Harbor, Ohioand 21 miles east from Toledo, Ohio. The exclusion area boundary has a minimum radius of 2400 feet from the center of the plant.

5.2 (Deleted) 4.2 5.3 Reactor Core 4.2.1 5.3.1 Fuel Assemblies The reactor core shall contain 177 fuel assemblies.:Each assembly shall consist ofa matrix of zircaloy M5, or ZIRLO cl)ad fuel rods with an initial composition of natural or slightly enriched uranium dioxide (UO2 ) 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 non-limiting core regions.

4.2.2 5.3.2Cntol Rod.

The reactor-core shall contain 53 safety and regulating control rod assemblies and 8 axial power shaping rod (APSR) assemblies. The nominal values of absorber material for the LAQi safety and regulating control rods shall be 0 centlsilver, fdium and[/

per ent cdmium. The absorber material for the APSRs shall be 10 jrnt nconel.

LA (Deleted) 5.5 (Deleted) 4.3 5.6 Fuel Storage 4.3.1 S.6.1 Criticality 4.3.1.2 5.6.1.1 The new fuel storage racks are designed and shall be maintained with:

4.3.1.2.b a. A Keff equivalent to less than or equal to 0.95 when flooded with unborated water, which includes ýaconservative allow; erof 1% deta - or uncertainties as described in Section 9.1 of the USAR. - LAO DAVIS-BESSE, UNIT I 5-1 Amendment No. 170, 179, 204, 237, 239, 247, 2(6 Page 1 of 3 Attachment 1, Volume 15, Rev. 1, Page 5 of 17

Attachment 1, Volume 15, Rev. 1, Page 6 of 17 ITS 4.0 ITS Design Features 510 5.0 DESIGN FEATUREES 5.6 Fuel Storage (continued) 4.3.1-2.c b. A Kcfr equivalent-to less than or equal to 0.98 when immersed inn: hydrogenous "mist" lof such a densityhtprovides optimum moderatio~n-(i-',e,, highest value of R*which includcsla conservative allov,**-e of 1% delTt-a lk-Fforuncertaintles

-as described in Section 9.1 of the USAR.

4.3.1.2.d e. A nominal 21inch center-to-center distance between fuel assemblies placed in the storage racks.

4.3.1.2.a d. Fuel assemblies having a maximum initial enrichment of 5.0 wcight percent uranium-235..!

4.3.1.1 5.6.1.2 Theý s spent fuel pool storage racks ate designed and shall be maintained with:

4.3.1.1.a a. A Kr. equivalent to less than or equal to 0.95 when flooded with unborated water, which includes a -conservativeajltowancefiartanu factu, ing tolerances L00 ladc*lainIuncertainty.

4.3.1.1.b b. A rectangular array Vf stainless steel cells with walls Pff0.075 inches nnminal ]-LAO4 thickness,/spaced a nominal 9.22 inches on center in both directions, a neutron absqrber material is utitizcd between cagh cell for critica ity]

consideratins.

4.3.1.1.c c. Fuel assemblies stored in the spent fuel pool in accordance with Technical Specification 3.9.13.

DAVIS-BESSE, UNIT I 5-2 Amernvmcnt No. 237, 247, 26*

Page 2 of 3 Attachment 1, Volume 15, Rev. 1, Page 6 of 17

Attachment 1, Volume 15, Rev. 1, Page 7 of 17 ITS 4.0 ITS Design Features 5.0 DESIGN FEATURES 5.6 Fuel Storage (continued) 4.3.2 5.6.2 Draina" The spent fuel storage pool, cask pit, and transfer pit are designed and shall be maintained to prevent inadvertent draining below 9 feet above the top of the fuel storage racks.

4.3.3 5.6.3 Catacirv The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than 1624 fuel assemblies. f!

5.7 (Deleted)

DAVIS-BESSE, UNIT I 5-3 Amendment No. 204, 237, 247 266 Page 3 of 3 Attachment 1, Volume 15, Rev. 1, Page 7 of 17

Attachment 1, Volume 15, Rev. 1, Page 8 of 17 DISCUSSION OF CHANGES ITS 4.0, DESIGN FEATURES ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 5.3.2 contains details of the percentage of each absorber material. The ITS does not contain these details, but includes the type of absorber material. This changes the CTS by moving the detailed description of the percentage of each type of absorber material to the UFSAR.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains requirements on the control rod material in ITS 4.2.2 and on control rod OPERABILITY in ITS Section 3.1. Also, this change is acceptable because the removed information will be adequately controlled in the UFSAR. Any changes to the UFSAR are made under 10 CFR 50.59 or 10 CFR 50.71(e), which ensures changes are properly evaluated. This change is designated as less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA02 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS 5.6.1.1.a and CTS 5.6.1.1.b contain details of the uncertainty allowances value (1% A k/k) for Keff equivalent for the new fuel storage racks. CTS 5.6.1.2.b contains details of the type of uncertainty allowances (manufacturing tolerances and calculation uncertainties) for the spent fuel pool storage racks. The ITS does not contain these details, but still states that the Keff equivalent includes uncertainties as described in Section 9.1 of the UFSAR. This changes the CTS by moving the detailed description of the Keff Davis-Besse Page 1 of 3 Attachment 1, Volume 15, Rev. 1, Page 8 of 17

Attachment 1, Volume 15, Rev. 1, Page 9 of 17 DISCUSSION OF CHANGES ITS 4.0, DESIGN FEATURES equivalent uncertainty allowance value and type of uncertainty allowances to the UFSAR.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains requirements on the Keff equivalent for unborated water and hydrogenous mist, as applicable. Also, this change is acceptable because the removed information will be adequately controlled in the UFSAR. Any changes to the UFSAR are made under 10 CFR 50.59 or 10 CFR 50.71(e), which ensures changes are properly evaluated. This change is designated as less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA03 (Type 1 - Removing Details of System Design and System Description,Including, Design Limits) CTS 5.6.1.1 .b, in part, states that new fuel storage racks are designed and maintained with a Keff equivalent to less than or equal to 0.98 when immersed in a hydrogenous mist "of such density that provides optimum moderation (i.e., highest value of Keff)." ITS 4.3.1.2.c states that new fuel storage racks are designed and maintained with keff < 0.98 "when immersed in a hydrogenous mist." This changes the CTS by moving the statement "of such density that provides optimum moderation (i.e., highest value of Keff)" to the UFSAR.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains requirements on the Keff equivalent when immersed in a hydrogenous mist. Also, this change is acceptable because the removed information will be adequately controlled in the UFSAR. Any changes to the UFSAR are made under 10 CFR 50.59 or 10 CFR 50.71(e), which ensures changes are properly evaluated. This change is designated as less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LA04 (Type I - Removing Details of System Design and System Description,Including Design Limits) CTS 5.6.1.2 and CTS 5.6.1.2.b state that spent fuel storage pool racks are designed and maintained with a rectangular array of stainless steel cells with walls of 0.075 inches nominal thickness spaced a nominal 9.22 inches on center in both directions, and that boral neutron absorber material is utilized between each cell for criticality considerations. ITS 4.3.1.1 and ITS 4.3.1.1.b state that the spent fuel pool storage racks are designed and maintained with a nominal 9.22 inch center to center distance between fuel assemblies. This changes the CTS by moving the details that the spent fuel storage pool racks are "high density" racks, the description of the array (type, composition, and wall size) and that neutron absorber material is used to the UFSAR.

The removal of these details, which are related to system design, from the

.Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate Davis-Besse Page 2 of 3 Attachment 1, Volume 15, Rev. 1, Page 9 of 17

Attachment 1, Volume 15, Rev. 1, Page 10 of 17 DISCUSSION OF CHANGES ITS 4.0, DESIGN FEATURES protection of public health and safety. The ITS still retains requirements for the spent fuel storage racks and center to center distance between fuel assemblies.

Also, this change is acceptable because the removed information will be adequately controlled in the UFSAR. Any changes to the UFSAR are made under 10 CFR 50.59 or 10 CFR 50.71(e), which ensures changes are properly evaluated. This change is designated as less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES None Davis-Besse Page 3 of 3 Attachment 1, Volume 15, Rev. 1, Page 10 of 17

Attachment 1, Volume 15, Rev. 1, Page 11 of 17 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 15, Rev. 1, Page 11 of 17

Attachment 1, Volume 15, Rev. 1, Page 12 of 17 CTS Design: Features 4.0 4.0 DESIGN FEATURES 5.1 4.1 Site Location

[Text 5cription of site cation. ] 0 5.3 4.2 Reactor Core 5.3.1 4.2.1 Fuel Assemblies M5 The reactor shall contain 1171 fuel assemblies. Each assembly shall consist of a matrix ofýZircallo or ZIRLOJ fuel rods with an initial composition of natural or slightly enriched uranium dioxide (UO2) 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.

5.3.2 4.2.2 Control Rods The reactor core shall contain Gas Oafe*t anqi4egulating CONTROL ROIDVL" and P8 APSRIassepbhies The material shall be Isilver indium

}00 cadmiu, boron carbide efhafnium metal as approved by the NRC.

5.6 4.3 Fuel Storage L--.* for the CONTROL RODS and Inconel for the APSRs, I 5.6.1 4.3.1 Criticality 5.6.1.2 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

0

a. Fuel asse nies having a maximum U-2>3'enrichment of

[4.5] we*jht percent, 71 0

0 5.6.1.2.a keff - 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in 1Section 9.1 of the 000@

Y A nominal inch center to center distance between 5.6.1.2.b fuel assemblies placed in [the high densiy fuel storage racks]6 A. and

[d. A nominal Winch center to center distancoetween fuel assemb*s placed in [the low density f~pl storage racks],]

0 BWOG STS .4.0-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 15, Rev. 1, Page 12 of 17

Attachment 1, Volume 15, Rev. 1, Page 13 of 17 4.0 CTS INSERT 1 5.1 The Davis-Besse Nuclear Power Station is located on Lake Erie in Ottawa County, Ohio, approximately six miles northeast from Oak Harbor, Ohio and 21 miles east from Toledo, Ohio, The exclusion area boundary has a minimum radius of 2400 feet from the center of the plant.

Insert Page 4.0-1 Attachment 1, Volume 15, Rev. 1, Page 13 of 17

Attachment 1, Volumne 15, Rev. 1, Page 14 of 17 CTS Design Features 4.0 4.0 DESIGN FEATURES 4.3 Fuel Storage (continued) [ Fuel assemblies stored in the spent fuel storage racks in accordance with LCO 3.7.16.

5.6.1.2.c Fr-Q IL011. New or partially sj 'ent fuel assemblies with a disoarge burnup in ID-T the "acceptableXange" of Figure [3.7.17-1] maybe allowed unrestricted orage in [either] fuel storage rpk(s), and ] 0

[ f. New or partiallyspent fuel assemblies with a dis arge burnup in the 'unaccep ble range' of Figure [3.7.17-1] w be stored in compliancevth the NRC approved [specific cument containing 0 the analytidal methods, title, date, or specific configuration or figure]. ] /

5.6.1.1 4.3.1.2 The new fuel storage racks are designed and shall be maintained with:

5.6.1.1.d a. Fuel assemblies having a maximum U-235 enrichment of 5.6.1.1.a

_ weight percen6+4 00

b. ketff - 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in ISection 9.1 of the 01 a_ -SAR*.L.* __ when immersed in a hydrogenous mist D00 5.6.1.1.b c. kf 5 0.981if moderated ya queous foam which includes an allowance for uncertainties as described in ISection 9.1 of the 400 FSAR (

d D00 5.6.1.1.c d. A nominal 121M.15 inch center to center distance between fuel assemblies placed in the storage racks. 0 5.6.2 4.3.2 Drainage The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool belowlelevation [13"ft inc es 43 Cact9 feet above the top of the 0

5.6.3 4.3.3 C y i7 spent fuel storage racks The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than con nrs fuel assemblies [and six ile fu-e t~~~1624 0 BVWOG STS 4.0-2 Rev. 3.0, 03131/04 Attachment 1, Volume 15, Rev. 1, Page 14 of 17

Attachment 1, Volume 15, Rev. 1, Page 15 of 17 JUSTIFICATION FOR DEVIATIONS ITS 4.0, DESIGN FEATURES

1. The brackets have been removed and the proper plant specific information/value has been provided.

2. ISTS 4.2.2 requires a certain number of "safety and regulating CONTROL ROD assemblies." The term "CONTROL ROD" is defined in ISTS 1.1 as "all full length safety and regulating rods that are used to shut down the reactor and control power level during maneuvering operations." Since the defined term "CONTROL ROD" already includes the type of rods (safety and regulating), the inclusion of these two types and the word "assemblies" in ISTS 4.2.2 is unnecessary and redundant.

Therefore, the words have not been included in ITS 4.2.2.

3. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

4. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

5. The ISTS 4.3.1.1 .a requirement to specify the maximum U-235 enrichment for the spent fuel storage pool racks has not been included in the Davis-Besse ITS. The Davis-Besse CTS, as well as NUREG-1430, Rev. 3.1, include a limit on keff for the spent fuel storage pool racks. In order to demonstrate compliance with this requirement, calculations have been performed, as described in the UFSAR, to determine the maximum keff of the racks. These calculations are dependent on the actual U-235 enrichment of the fuel stored in the racks. For ease of demonstrating compliance with the keff limit for the Davis-Besse rack design, a bounding compliance criterion for each fuel type that can be stored in the new and spent fuel storage racks has been established such that the keff limit is still met. Because Davis-Besse is required to maintain the keff < 0.95, each new fuel assembly loaded into the reactor must be compared to the storage racks bounding compliance criterion. This new limitation is a design feature of the fuel, not the racks. Furthermore, ITS 3.7.16 places limitations on storage of spent fuel in the spent fuel storage pool racks.

Design reviews for reloads will also verify continued compliance with the bounding requirements prior to storing the fuel in the new fuel storage racks and using the new fuel. This ensures continued compliance with the current keff limit for the new and spent fuel storage racks as required by the current Davis-Besse Technical Specifications. The following requirements have been renumbered, as applicable, to reflect this deletion.

6. The spent fuel pool storage racks are all high density racks. Therefore, ISTS 4.3.1.1.d has not been included in the Davis-Besse ITS and the ISTS 4.3.1.1.c (ITS 4.3.1.1.b) clarifying term "placed in the high density fuel storage racks" has been deleted. Furthermore, ISTS 4.3.1.1 .e and f provide the requirements for loading fuel in accordance with ISTS Figure 3.7.17-1 (Note that this Figure is actually in ISTS 3.7.16). The Davis-Besse requirements have been included in ITS 4.3.1.1.c, and only allow fuel to be loaded in accordance with LCO 3.7.16 - no exceptions are allowed. Due to the deletion of ISTS 4.3.1.1 .d, the following requirements have been renumbered, as applicable.

Davis-Besse Page 1 of 1 Attachment 1, Volume 15, Rev. 1, Page 15 of 17

Attachment 1, Volume 15, Rev. 1, Page 16 of 17 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 15, Rev. 1, Page 16 of 17

Attachment 1, Volume 15, Rev. 1, Page 17 of 17 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 4.0, DESIGN FEATURES There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1,Volume 15, Rev. 1, Page 17 of 17