SBK-L-13224, Request for Review and Approval of License Amendment Request (LAR) 11-04, Changes to Technical Specifications for New and Spent Fuel Storage, in Two Parts

Request for Review and Approval of License Amendment Request (LAR) 11-04, Changes to Technical Specifications for New and Spent Fuel Storage, in Two Parts

ML13360A045
Person / Time
Site:	Seabrook
Issue date:	12/20/2013
From:	Walsh K NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR 11-04, SBK-L-13224
Download: ML13360A045 (25)

Text

{{#Wiki_filter:NEXTera ENERY" I December 20, 2013 SBK-L-13224 Docket No. 50-443 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Seabrook Station Request for Review and Approval of License Amendment Request (LAR) 11-04, Changes to Technical Specifications for New and Spent Fuel Storage, in Two Parts

References:

1. NextEra Energy Seabrook, LLC letter SBK-L-1 1245, "License Amendment Request 11-04, Changes to the Technical Specifications for New and Spent Fuel Storage,"

January 30, 2012

2. NRC letter "Seabrook Station, Unit No. 1 - Supplemental Information Needed for Acceptance of Requested Licensing Action Regarding License Amendment Request 11-04, Changes to the Technical Specifications for New and Spent Fuel Storage (TAC No. ME7946)," March 30, 2012

3. NextEra Energy Seabrook, LLC letter SBK-L-12099, "Supplement to LAR 11-04, Changes to the Technical Specifications for New and Spent Fuel Storage," May 10, 2012

4. NRC Letter "Seabrook Station, Unit No. 1 - Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage (TAC No. ME8688)," July 24, 2012

5. NextEra Energy Seabrook, LLC letter SBK-L-12199, "Response to Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage," September 20, 2012

6. NRC Letter "Seabrook Station, Unit No. 1 - Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage (TAC No. ME8688)," December 5, 2012

7. NextEra Energy Seabrook, LLC letter SBK-L-1 3061, "Response to December 2012 Request for Additional Information Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage," March 27, 2013 NextEra Energy Seabrook, LLC.

626 Lafayette Rd, Seabrook, NH 03874 A ba

United States Nuclear Regulatory Commission SBK-L-13224 / Page 2 In Reference 1 and supplemented by References 3, 5, and 7, NextEra Energy Seabrook, LLC (NextEra) submitted a request for an amendment to the Technical Specifications (TS) for Seabrook Station. The proposed change would revise the TS for new and spent fuel storage as the result of new criticality analyses for the new fuel vault and the spent fuel pool. As discussed in a conference call with the NRC on December 4, 2013, the staff has completed its review of the criticality analysis related to the spent fuel pool storage portion of the LAR; however, review of the analysis related to the new fuel vault storage will continue well into 2014. As a result, NextEra proposes that the NRC review and approve the proposed changes in LAR 11-04 in two segments. The first segment would include approval and issuance of an amendment with the TS changes involving only spent fuel pool storage. Review of the criticality analysis and associated TS changes related to new fuel vault storage would continue, and a separate amendment for the changes related to new fuel vault storage would be issued following the NRC staff's review and approval of the proposed changes. The suggested approach would allow the NRC staff to close its review of the spent fuel pool storage portion of the LAR and provide NextEra with updated TS for spent fuel pool storage. To support separating the LAR review and approval into two parts, Attachments 1 and 2 provide separate markups of the proposed TS changes for each segment. Attachment 1 provides markups of the TS for proposed changes related only to the spent fuel pool storage portion of the LAR. Attachment 2 contains markups for TS changes related to new fuel vault storage. The Attachments only separate the proposed changes into two parts and do not materially alter the proposed changes from those originally submitted in References 1, 3, 5, and 7. This proposed change does not alter the conclusion in Reference 1 that the proposed change does not involve a significant hazards consideration pursuant to 10 CFR 50.92. Provided for information only in Attachments 3 and 4 are markups of the proposed TS Bases changes for the spent fuel pool storage portion and the new fuel vault storage portion of the LAR, respectively. Reference 1 included a markup of changes to the TS index. However, on June 17, 2013, the NRC issued Amendment 137, which removed the index from the TS. Therefore, a TS index is not included in the TS markups in Attachments 1 and 2 to this letter. Should you have any questions regarding this letter, please contact Mr. Michael Ossing, Licensing Manager, at (603) 773-7512. Sincerely, Kevin T. Walsh Site Vice President NextEra Energy Seabrook, LLC

United States Nuclear Regulatory Commission SBK-L-1 3224 / Page 3 - Markup of the TS for Spent Fuel Storage Portion of LAR 11-04 - Markup of the TS for New Fuel Storage Portion of LAR 11-04 - Markup of the TS Bases for Spent Fuel Storage Portion of LAR 11-04 - Markup of the TS Bases for New Fuel Storage Portion of LAR 11-04 cc: NRC Region I Administrator J. G. Lamb, NRC Project Manager NRC Senior Resident Inspector

ATTACHMENT 1 Markup of the TS for Spent Fuel Storage Portion of LAR 11-04

REFUELING OPERATIONS 3/4,913 SPENT FUEL ASSEMBLY STORAGEQ LIMITING CONDITION FOR OPERATION 3.9J3 Fuel assemblies stored In the Spent Fuel Ishall beplaced Inthe spent fuel storage racks .according to the criteria shown in I-rt'

• i- - ,..,

APPLICASILI'rY. Whenever fuel Is In the Spent Fuel Pool. ACTION:-

a. With the requirements of the above speplffbailon not. lsIed, suspend all other fuel movement within the Spent Fuel Pool and ove tile non-complying. "

fuelI to allow ns Inthe Spent Fuel Pool Inaccordance

b. The provisions of Specification 3.0.3 are not applicable.

I . SURVEILLANCE REQUIREMENTS .

            .913.1 Týhe burnup of each fuel assembly to bestored In the Spent Fuel Pool shall be determined from U'!s measured burnup history prior to storage as longIn.

asthethat fuel Puel Spent Pool. IsA assembly A complete record of each assembly shall be maintained Fuel Pool, the -{ movementinto or within theSpent 4,.0.3.2 "After fuel asseblxby(ies) moved shall *e checked and" [position of the fuel assembly(les) that was (were) 3/4 9-16 Amendment No. 6 SEABROOI(- UNIT "I

                           '1can be stored anywhere                  .*         ,1 2 must not be stored next11 Io3 3 must be stored next to I of amply locations TypelI
  *.. 5,--       "       //---1                                      ~   i-"

2.6 2.76 3.0 3,26 3.6 3.75 4,0 4.26 4.5 . 41.75 6.0 Inltlal Enrichment w U235) Figure 3,9..1 Fuel Assembly Burnup vs. InItlal Enric ont

                         .or Spent Fuel Assembty Storage SEABROOK- UNIT 1                            3/4 9-17                               mendment No. 6

X..':~ *Jr.fl~tAl.*.~.%t~t~* *1* *..-..,... - REFUELING OPERATIONS a. 13/4,,15 SPENT FUEL POOL BORON CONCENTRATION LIMITING CONDITION FOR OPERATION 3.9.15 The boron concentration In the Spent Fuel Pool shall be greater than or equal to 2000 ppm. APPLICABILITY: Whenever fuel Is In the Spent Fuel Pool ACTION

a. With boron concentration In the Spent Fuel Pool, less than 2000 ppm, immediately suspend movement of fuel In the Spent Fuel Pool and Immediately initiate actlon to rostore boron concentratlon to 2000 ppm or greater.

b. The provisions of Specification 3,0.3 are not applicable.

GURVEILLANCE REgQUiREMENTS 4.9.15.1 The boron concentrallon of the Spent Fuel Pool shall be verified to be 2000 ppm or greater at least once per 7 days, SEABROOK-1 MIT I 9-17 13/4 SBBOOKtINT Amendm~jit No.

     .... I.......

DESIGN FEATURES 5.6 FUEL STORAGE CRITIOALIT.Y 6.6.1.1 e spent fuel storage racks are designed and shall be maintained with:

a. Ak R-eval-ent to less than or equal to an flooded with unborat

             ,--Water, which Includes margin for i. eegilnty In calculation methodr mechanical tolerances with 6%probabillty at a 95 CO ldnce level.

b. A nominal 10.356 center-to-center distance ] een fuel assemblles placed in the storage racks.

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

a. A k.11 equivalent to less than or equal to 0.95 when flooded with unborated water, which Includes margin for uncertainty Incalculational methods and mechanical tolerances with a 95% probability at a 95% confidence level.

b. A ke11 equivalent to less than or equal t( 0.98 when aqueous foam moderat ton is assumed, which Includes margin for uncertainty In calculational methods and mechanical tolerances with a 95% probability at a 95% confidence leW C. A nominal 21 inch center-to-center distance between fuel assemblies place din the storage racks.

PRAINA~g 56A2 The spent fuiel storage pool Isdesigned and shall be maintained to prevent Inadvertent draining of the pool below elevation 14 feet 6 Inches. CAPACITY 6,6.3 The spent fuel storage pool Isdesigned and shall be maintained with a storage capacity limited to no more than 1236fuel assemblies. 5.7 COMPONENT CYCLIC OR TRANSIENT LIMIT 5.7.1 The components Identified InTable 6.7-1 are designed and shall be maintained within the cyclic or transient limits of Table 6.7-1. SEABROOK - UNIT 1I1 Amendment N0o.-6---- I

INSERT 5.6.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. A keff less than 1.0 when flooded with unborated water, which includes an allowance for biases and uncertainties as described in UFSAR Chapter 9.

b. A ket less than or equal to 0.95 when flooded with water borated to 500 ppm, which includes an allowance for biases and uncertainties as described in UFSAR Chapter 9.

c. A nominal 10.35 inch center-to-center distance between fuel assemblies placed in the storage racks.

INSERT 5.6.1.3 5.6.1.3 Fresh or irradiated fuel assemblies shall be stored in the spent fuel pool in compliance with the following:

a. Any 2x2 array of Region 1 storage cells containing fuel shall comply with the storage pattern in Figure 5.6-1 and the requirements of Table 5.6-1. The reactivity ranks of fuel assemblies in the 2x2 array (rank determined using.

Table 5.6-1) shall be equal to or less than defined for the 2x2 array.

b. Any 2x2 array of Region 2 storage cells containing fuel shall comply with the storage requirements defined in Figure 5.6-2 and the requirements of Table 5.6-1 or with the allowable exception of evaluated assemblies stored on the periphery of Region 2 as defined in 5.6.1.3.c. The evaluated assemblies are listed in Table 5.6-2.

c. 2x2 arrays fully within the first two rows closest to the West Wall composed only of fuel assemblies documented in Table 5-6.2 or empty locations, are allowed without having to meet the storage requirements defined in Figure 5.6-2 and the requirements of Table 5.6-1.

d. In addition to meeting the requirements defined in 5.6.1.3.a, fuel assemblies placed in Region I in the row adjacent to Region 2 shall continue the Region 2 patterns as defined in Figure 5.6-2 and shall meet the associated Region 2 reactivity class requirements.

e. Any fuel assembly (with or without an RCCA) may be replaced by an empty water cell, non-fuel hardware or a fuel rod storage basket.

Table 5.6-1 BURNUP REQUIREMENTS FOR EACH REACTIVITY CLASS Bounding Polynomial Fits for Minimum Burnup Requirements See Notes 1,2 and 3 for use of Table 5.6-1 Reactivity Cooling Class (1) Time Coefficient A() Coefficient B Coefficient C RC 1(3) N/A N/A N/A N/A RC 2 N/A -23.9486 7.4857 0.0000 Enrichment <3.6 w/o Enrichment > 3.6 w/o Coefficients Coefficients A B C A B C 0 years -46.4893 24.2342 -1.4689 -46.9639 23.9883 -1.4535) 2.5 years -45.3671 23.6083 -1.4430 -44.6422 22.7925 -1.3592 RC 3 5 years -43.3626 22.3467 -1.2912 -42.8691 21.5892 -1.2031 10 years -41.2729 21.3176 -1.2238 -40.4786 20.4229 -1.1214 15 years -37.5450 19.2208 -0.9792 -36.5543 18.2164 -0.8607 20 years -37.1511 19.1067 -0.9965 -35.8945 17.9317 -0.8518 0 years -39.4986 24.8329 -1.4714 -35.5129 22.5425 -1.2508 2.5 years -42.0614 26.2021 -1.7536 -31.0986 20.3032 -1.0635 5 years -43.5036 26.7220 -1.8423 -28.4171 18.8863 -0.9270 10 years -40.2450 24.8908 -1.6792 -32.5900 20.6289 -1.1778 15 years -39.4193 24.3389 -1.6482 -35.7271 22.0541 -1.3825 20 years -38.0193 23.4289 -1.5482 -33.6429 20.7970 -1.2397 0 years -18.6729 17.1776 -0.3238 15.4943 0.4484 1.5317 2.5 years -22.0079 18.6718 -0.6196 27.0014 -5.0979 2.0587 RC 5 5 years -24.5664 19.9913 -0.8744 20.9571 -2.1108 1.6159 10 years -25.9493 20.7089 -1.0982 -0.9900 8.4067 0.2667 15 years -26.8021 21.1"165 -1.2220 -13.6314 14.4202 -0.5032 20 years -26.3500 20.8067 -1.2333 -20.7757 17.7162 -0.9238 SEABROOK - UNIT I 5-11 Amrendment No.

Table 5.6-1 (continued) BURNUP REQUIREMENTS FOR EACH REACTIVITY CLASS Bounding Polynomial Fits for Minimumn Burnup Requirements See Notes 1, 2 and 3 for use of Table 5.6-1 Notes

1. Reactivity Classes are presented from High to Low, e.g., RC 1 is most reactive fuiel, RC 5 is least reactive fuel.

2. The specific minimum burnup (Bu) required for each fuel assembly for Reactivity Classes 2-5 are calculated from the following equation:

Bu = A + BxEn +Cx En 2 where the coefficients A, B and C are defined above for each Reactivity Class and cooling time (if applicable) and En is defined as the nominal initial central zone enrichment. Actual cooling time is rounded down to the nearest value, e.g., an assembly with an actual cooling time of 12 years would utilize the10 year coefficients. No uncertainties should be applied when determining the minimum burmup requirement; all appropriate uncertainties have been included during the coefficient generation.

3. Fresh or irradiated fuel with an initial enrichment of_< 5.0 w/o U-235.

SEABROOK - UNIT 1 5-12 Amendment No

Table 5.6-2  ! EVALUATED ASSEMBLIES ON PERIPHERY OF REGION 2 i i. coal 01733 049 C02 c03 C04

               -18 Ci1 C20 034 c38 037 cs0 051 C52 I.

C05 C21 038 C63 COo C22 039 066 C07 C23 C40 C56 c09 C24 C41 C7 C10 C26 042 c08 c1 . C27 C43 059 012 c28 C44 c60 C18 029 C45 0ol C14 030 C46 C62 15 _C31 04- c63

        " 0 cC32                           c48         C64 SEABROOK -UNIT I               5-13          Amendment No.

ALLOWABLE STORAGE PATTERN REGION I (See Notes 1 and 2) Pattern "A" See Definition I DEFINITIONS:

1. Allowable pattern is fuel assemblies that meet Reactivity Class (RC) 1, 2, 3, 4, or 5 checkerboarded with fuel assemblies that meet RC 2, 3, 4, 5. Requirements for all RC are defined in Table 5.6-1. Diagram is for illustration only.

NOTES

1. There are no interface limitations within Region 1 between rack modules or within racks. Each cell is a part of up to four 2x2 arrays, and each cell must simultaneously meet the requirements of all those arrays of which it is a part.

2. Replacement of any fuel assembly by an empty water hole, non-fuel hardware or fuel rod storage basket is acceptable.

Figure 5.6-1 SEABROOK - UNIT 1 5-14 Amendnient No.

ALLOWABLE STORAGE PATTERNS REGION 2 (See Notes 1, 2) Pattern "B" Pattern "C" Pattern "D" RC3 RCCA LuCi [Cfin RC 5 3 R3 RC3 See Definition I See Definition 2 Lieeoefijjton 3 DEFINITIONS

1. Allowable pattern is fuel assemblies that meet Reactivity Class (RC) 3 4, or 5 in each of the 2x2 array locations combined with two RCCAs placed in any two locations within the 2x2 array. Requirements for all RC are defined in Table 5.6-1. Replacement of any fuel assembly (with or without an RCCA) by an empty water hole, non-fuel hardware or fuel rod storage basket is acceptable. Diagram is for illustration only.

2. Allowable pattern is fuel assemblies that meet Reactivity Class (RC) 4 or 5 in each of the 2x2 array locations with one RCCA placed anywhere in the 2x2 array. Requirements for all RC are defined in Table 5.6-1.

Replacement of any fuel assembly (with or without an RCCA) by an empty water hole, non-fuel hardware or fuel rod storage basket is acceptable. Diagram is for illustration only.

3. Allowable pattern is Reactivity Class (RC) 5 in each of the 2x2 array locations. Minimum bumup for RC 5 is defined in Table 5.6-1 as a function of nominal initial central zone enrichment and cooling time. Replacement of any fuel assembly by an empty water hole, non-fuel hardware or fuel rod storage basket is acceptable.

Diagram is for illustration only. NOTES

1. The storage arrangements of fuel within a rack module may contain more than one pattern. There are no interface limitations within Region 2 between rack modules or within racks. Each cell is a part of up to four 2x2 arrays, and each cell must simultaneously meet the requirements of all those arrays of which it is a part.

2. All permanent and transient configurations for fuel placed within Region 2 must meet the requirements of Figure 5.6-2 and Table 5.6-1.

Figure 5.6-2 SEABROOK - UNIT 1 5-15 Amendmnent No.

                                                                                                          .1 TABLE 5.7-1 COMPONENT CYCUC.OR TRANSIENT U?MATS DESIGN CYCLE CYCUIC OR COMPONENT                TRANSIENT UMIT                     OR TRANSIN-T Reactor Coolant System   200 heatup cycles at -100*F/I,     Heatup cycle - Tavs from _<200OF to 2 5500 F.

and 200 coofdown cycles at _<I00F/h Cooldown cycle - Ta,, fromn __5502F to

                                                           <2000F.

200 pressurizer cooldown cycles Pressu rizer cooldown cycle temperatures at : 2001nh. from Z6501F to ýg 200=F. 80 loss of load cycles, wi tnout > 15% of RATED THERMAL POWER to immediate Reactor trip,. 0% of RATED THERMAL POWER. 40 cycles of loss-of-offsite Loss-of-offsite A.C. electrical ESF Electrical A.C. electrical power. System. 80 cycles of loss of flow in one Loss of only one reactor coolant pumpL reactor coolant .cop. 400 Resactor trip cycles. 100% to 0% of RATED THERMAL POWER. Spray water temperature differential 10 auxiliary spray actuation cycles. > 320 0F. 200 leek tests. Pressuized to' 2250 psig. 10 hydrostatc pressure tests. Pressurized to k 3106 psig. Secondary Coolant System I steam line break. Break in a > 6-inch steam line. 10 hydrostatic pressure tests. Pressurized to '_ 1481 psig.

                                                      .'*7 SEABROOK - UNIT I

ATTACHMENT 2 Markup of the TS for New Fuel Storage Portion of LAR 11-04

REFUELING OPERA-TIONS 314.9.14 EW FUELA SEM3Y S-0GEr

                   ....I   Fo -okl ULIMITING CONDITION FOR OPERATIO/-Y`

3.9.14 The New Fuel6 Storage Vault may be maintained with a full loading of 90 assemblies with fuel enrIchment Up to 3.676 0/o 235U. The loading must be reduced to 81 assemblies for enrichments from 3.675 to 5.0 w/o 2U by limiting the fuel assernbly placement In the central column of the New Fuel Storage Vault to every other location. APPLICABILITY; Whenever fuel Is In the New Fuel Storage Vaull. ACTION

a. With the requirements of the above specification not satisfied, suspend all other fuel. movement wIthin the New Fuel Storage Vault and move ihe nonn-complying fuel assemblies to allowable locations In the New Fuel Storage Vault In accordance with Ihe requIrements of the above upeclilcation.

b. The provislons of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.14.1 After fuel aesemnbly(Ies) movement Into or within fthNew Fuel Storage Vault, the position of the new fuel assemnbly(les) that was (wore) moved shall bý checked and Independently verified to be in accordance with the requirements of the above specification. SEABROOJ - UNIT i 3/4 9-18 Amendment NO

DESIGN FEATURES 5.6 FUEL STORAGE CRITICALIT 5.6.1.1 The spent fuel storage racks are desIgned and shall be mainlained with:'

a. A ken equivalent to less than or equal to 0.95 when flooded with unborated water, which Includes margin for uncertainty in calculation methods and mechanical tolerances with a 95% probability at a 95% confidence level.

b. A nominal 10.35 Inch center-to-center distance between fuel assemblies placed In the storage racks.

5.6.1.2 The new fuel storage racks are designed and shall be maintalned wth:

a. A ken equivalent to.lAesa-than or equal to 0.96 when ooded with unborated water, which I 0aes margin for uncertaintyy.J alculational methods and mecha olerances with a 96% pro lty at a 95% confiden Vel

b. ken equivalent to less than o qual to 0.98 when aque foam moderation

             ," Is assumed, whoich Include    .. argln for uncertainty I.e.rolulational methods       l .,

c. A nominal 21inch centeo-center distance beteen fuel assemblie aced in D)RAINAGE 5.6.2 The spent fuel storage pool Is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 14 feet 6 Inches.

CAPACITY 5.6.3 The spent fuel storage pool Is designed and shall be maintained with a storage capacity limited to no more than '1236 fuel assemblies. 5.7 COMPONENT CYCLIC OR TRANSIENT LIMIT 6.7.1 The components identified in Table 5.7-1 are designed and shall be maintained within the cyclic or transient limits of Table 5.7--1. SEABROOK - UNIT 1 56-10 AAmendmdnt No.4

INSERT 5.6.1.2

a. A keff equivalent to less than or equal to 0.95 when fully flooded with unborated water, which includes an allowance for biases and uncertainties as described in UFSAR Chapter 9.

b. A keff equivalent to less than or equal to 0.98 if moderated by aqueous foam, which includes an allowance for biases and uncertainties as described in USFAR Chapter 9.

c. At least a nominal 21 inch center-to-center distance between fuel assemblies placed in the storage racks with a nominal 33 inches center-to-center distance (east to west) between fuel assemblies in the center column and adjacent columns.

ATTACHMENT 3 Markup of the TS Bases for Spent Fuel Storage Portion of LAR 11-04

3/4.9 REFUELING OPERATIONS (Continued) BASES 3/4.9.9 (THIS SPECIFICATION NUMBER IS NOT USED.) 3/4.9.10 and 3/4.9.11 WATER LEVEL - REACTOR VESSEL and STORAGE POOL The restrictions on minimum water level ensure that sufficient water depth is available to remove 99% of the assumed 10% iodine gap activity released from the rupture of an irradiated fuel assembly. The minimum water depth is consistent with the assumptions of the safety analysis. Suspending fuel movement or crane operation does not preclude moving a component to a safe location. 3/4.9.12 FUEL STORAGE BUILDING EMERGENCY AIR CLEANING SYSTEM The limitations on the Fuel Storage Building Emergency Air Cleaning System ensure that all radioactive material released from an irradiated fuel assembly will be filtered through the HEPA filters and charcoal adsorber prior to discharge to the atmosphere. Operation of the system with the heaters operating for at least 10 continuous hours in a 31-day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters. The OPERABILITY of this system and the resulting iodine removal capacity are consistent with the assumptions of the safety analyses. ANSI N510-1980 will be used as a procedural guide for surveillance testing. Suspending fuel movement or crane operation does not preclude moving a component to a safe location. One train of the Fuel Storage Building Emergency Air Cleaning System must be in operation during fuel movement. This requirement, however, does not apply to movement of a spent fuel cask containing irradiated fuel in preparation for transfer to dry storage. Movement of fuel after it has been inserted into a spent fuel cask and unlatched from the lifting tool is no longer a consideration with regard to this specification. 3/4.9.13 SPENT FUEL ASSEMBLY STORAGE Restrictions I Poolison pla dicat~ t of fuel igue 3.9-. assemblies of s.atn Thes red enrichments within the Spent nsurethat the Io*:*.pn Fuel Pool ways remain less than 0_ ssuming the pool to be floo* -- ith unborated wa he restrictions delineate igure 3.9-1 and the action s ment are consistent ith the criticality safety a 'sis performed for the Spent Fule ool as documented in the

FSAR, SEABROOK - UNIT 1 B 3/4 9-4 AmRe 6, 85, BC 0, -0, 08-10

3/4.9 REFUELING OPERATIONS (Continued') 3/4.9 REFUELING OPERATIONS (Continued) BASES 3/4.9.14 NEW FUEL ASSEMBLY STORAGE Restrictions on placement of fuel assemblies of certain enrichments within the New Fuel Storage Vault is dictated by Specification 3/4.9.14. These restrictions ensure that the Ke, of the New Fuel Storage Vault will always remain less than 0.95 assuming the area to be flooded with unborated water. In addition, these restrictions ensure that the Kef of the New Fuel Storage Vault will always remain less than 0.98 when aqueous foam moderation is assumed. The restrictions delineated in Specification 3/4.9.14 and the action statement are consistent with the criticality safety analysis performed for the New Fuel Storage Vault as documented in the FSAR. SEABROOK - UNIT 1 B 3/4 9-5 BC 08-10 1

INSERT 1 Restrictions on placement of fuel assemblies of certain enrichments within the Spent Fuel Pool is dictated by Specification 5.6.1.3. These restrictions ensure that the keff of the Spent Fuel Pool will always remain less than 1.0 assuming the pool to be flooded with unborated water and less than or equal to 0.95 when flooded with water borated to 500 ppm. The restrictions delineated in Specification 5.6.1.3 and the action statement are consistent with the criticality safety analysis performed for the Spent Fuel Pool as documented in the FSAR. INSERT 2 3'/4.9.15 SPENT FUEL POOL BORON CONCENTRATION The limitation on the Spent Fuel Pool boron concentration ensures that sufficient boron is present to maintain criticality margin during any potential spent fuel pool accident. The required boron concentration is also sufficient to ensure that no boron dilution event could reduce the spent fuel concentration below 500 ppm. The action statement requires immediately suspending movement of fuel until the boron concentration has been restored. This does not preclude movement of a fuel assembly to a safe position.

ATTACHMENT 4 Markup of the TS Bases for New Fuel Storage Portion of LAR 11-04

3/4.9 REFUELING OPERATIONS (Continued'* 3/4.9 REFUELIN OPERATIONS (Continued) Restrictions ollacement of fuel asseý-. s of certain enrichments within the New Fuel Sto-ra-ult is dictated by Spec ion 3/4.9.14. These restrictio nsure that the e K0 odedwithuborated e New Fuel Storage Va er. In

                                    -iiaddition, always remain    less than these restric "    0. ssuming   the area to ensure that the K of the New Fuel Storage Vill       always remain less tha             when aqueous foam motoa         n is assumed. Thrstrictions delineated in S             iation 3/4.9.14 and the act     s'rtatement are consist, with the criticality safety       yfsis performed for the New        Storage Vault/

s documented in the FSAR. SEABROOK- UNIT I B 3/4 9-5 BC 08-10 1}}