ML18016A859

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Notice of Consideration of Issuance of Amend to License NPF-63 & Proposed NSHC Determination & Opportunity for Hearing.Amend Would Support Mod to Plant to Increase Spent Fuel Storage Capacity by Adding Rack Modules to SFPs
ML18016A859
Person / Time
Site: Harris 
Issue date: 01/07/1999
From: Scott Flanders
NRC (Affiliation Not Assigned)
To:
Shared Package
ML18016A858 List:
References
NUDOCS 9903220195
Download: ML18016A859 (19)


Text

7590-01-P UNITED STATES NUCLEAR REGULATORYCOMMISSION CAROLINAPOWER 8 LIGHT DOCKET NO. 50-400 NOTICE OF CONSIDERATION OF ISSUANCE OF AMENDMENTTO FACILITYOPERATING LICENSE PROPOSED NO SIGNIFICANTHAZARDS CONSIDERATION DETERMINATION AND OPPORTUNITY FOR A HEARING The U.S. Nuclear Regulatory Commission (the Commission) is considering issuance of an amendment to Facility Operating License No. NPF-63 issued to Carolina Power 8 Light (CP8L or the licensee) for operation of the Shearon Harris Nuclear Power Plant located in Wake and Chatham Counties, North Carolina.

The proposed amendment would support a modification to the plait to increase the spent fuel storage capacity by adding rack modules to spent fuel pools (SFPs) 'C'nd 'D'nd placing the pools in service.

In order to activate the pools, CP8L requests that the NRC review and approve the following:

Revised Technical Specification 5.6 to identify PWR burnup restrictions, BWR enrichment limits, pool capacities, heat load limitations and nominal center-to-center distances between fuel assemblies in the racks to be installed in SFPs

'C'nd

'D.'0CFR50.55a Alternative Plan to demonstrate acceptable level of quality and safety in the completion of the component cooling water (CCW) and SFP

'C'nd

'D'ooling and cleanup system piping.

The cooling system for SFPs 'C'nd 'D'annot be N stamped in accordance with ASME Section III since some installation records are not available, a partial

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f turnover was not performed when construction was halted following the cancellation of Unit 2 and CP8 L's N certificate program was discontinued following completion of Unit 1.

iii.

Unreviewed safety question for additional heat load on the CCW system.

The acceptability of the 1.0 MBtu/hr heat load from SFPs 'C'nd 'D'as demonstrated by the use of thermal-hydraulic analyses of the CCW system under various operating scenarios. The dynamic modeling used in the thermal-hydraulic analyses identified a decrease in the minimum required CCW system flow rate to the residual heat removal heat exchangers.

This change has not been previously reviewed by the NRC and is deemed to constitute an unreviewed safety question.

Before issuance of the proposed license amendment, the Commission willhave made findings required by the Atomic Energy Act of 1954, as amended (the Act) and the Commission's regulations.

The Commission has made a proposed determination that the amendment request involves no significant hazards consideration.

Under the Commission's regulations in 10 CFR 50.92, this means that operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. As required by 10 CFR 50.91(a), the licensee has provided its analysis of the issue of no significant hazards consideration, which is presented below:

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Involve a significant increase in the probability or consequences of an accident previously evaluated.

In the analysis of the safety issues concerning the expanded pool storage capacity within Harris'uel Handling Building, the following previously postulated accident scenarios have been considered:

a.

A spent fuel assembly drop in a Spent Fuel Pool b.

Loss of Spent Fuel Pool cooling flow c.

A seismic event d.

Misloaded fuel assembly The probability that any of the accidents in the above list can occur is not significantly increased by the activity itself. The probabilities of a seismic event or loss of Spent Fuel Pool cooling flow are not influenced by the proposed changes. The probabilities of accidental fuel assembly drops or misloadings are primarily influenced by the methods used to liftand move these loads. The method of handling loads during normal plant operations is not signiflicantly changed, since the same equipment (i.e., Spent Fuel Handling Machine and tools) and procedures as those in current use in pools 'A'nd 'B'illbe used in pools 'C'nd 'D'. Since the methods used to move loads during normal operations remain nearly the same as those used previously, there is no significant increase in the probability of an accident. Current shipping activities at the Harris Nuclear Plant willcontinue as previously licensed. The consequences of an accident involving shipping activities [are] not changed and there is no significant increase in the probability of an accident.

During rack installation, all work in the pool area willbe controlled and performed in strict accordance with specific written procedures. Any movement of fuel assemblies which is required to be performed to support this activity (e.g., installation of racks) willbe performed in the same manner as during normal refueling operations.

Accordingly, the proposed activity does not involve a significant increase in the probability of an accident previously evaluated.

The consequences of the previously postulated scenarios for an accidental drop of a fuel assembly in the Spent Fuel Pool have been re-evaluated for the proposed change. The results show that such the postulated accident of a fuel assembly striking the top of the storage racks willnot distort the racks sufficiently to impair their functionality. The minimum subcriticality margin, Keff less than or equal to 0.95, willbe maintained. The structural damage to the Fuel Handling Building, pool liner, and fuel assembly resulting from a fuel assembly drop striking the pool floor or another assembly located within the racks is primarily dependent on the mass of the faIling object and the drop height. Since these two parameters are not changed by the proposed activity from those considered previously, the structural damage to these items remains

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~ unchanged. The radiological dose at the exclusion area boundary willnot be increased from those previously considered, since the pertinent fuel parameters remain unchanged. These dose levels remain "well within"the levels required by 10CFR100, paragraph 11, as defined in Section 15.7.4.ll.1 of the Standard Review Plan. Thus, the results of the postulated fuel drop accidents remain acceptable and do not represent a significant increase in consequences from any of the same previously evaluated accidents that have been reviewed and found acceptable by the NRC.

The consequences of a loss of Spent Fuel Pool cooling have been evaluated and found to have no increase. The concern with this accident is a reduction of Spent Fuel Pool water inventory from bulk pool boiling resulting in uncovering fuel assemblies. This situation would lead to fuel failure and subsequent significant increase in offsite dose. Loss of spent fuel pool cooling at Harris is mitigated in the usual manner by ensuring that a sufficient time lapse exists between the loss of forced cooling and uncovering fuel. This period of time is compared against a reasonable period to re-establish cooling or supply an alternative water source. Evaluation of this accident usually includes determination of a time to boil, which in the case of pools 'C'nd 'D's in excess of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> based on a consideration of end of plant life heat loads. This evaluation neglects any possible cooling from the connection to pools 'A'nd

'B'hrough the transfer canal. The 13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> period is much shorter than the onset of any significant increase in offsite dose, since once boiling begins it would have to continue unchecked until the pool surface was lowered to the point of exposing active fuel. The time to boil represents the onset of loss of pool water inventory and is commonly used as a gauge for establishing the comparison of consequences before and after a refueling project. The heatup rate in the Spent Fuel Pool is a nearly linear function of the fuel decay heat load. Subsequent to the proposed changes, the fuel decay heat load willincrease because of the increase in the number assemblies from those considered from Pools 'A'nd

'B'lone.

The methodology used in the thermal-hydraulic analysis determined the maximum fuel decay heat loads. In the unlikely event that pool cooling is lost to pools 'C'nd 'D', sufficient time willstill be available for the operators to provide alternate means of cooling before the onset of pool boiling. Therefore, the proposed change represents no increase in the consequences of loss of pool cooling.

The consequences of a design basis seismic event are not increased. The consequences of this accident are evaluated on the basis of subsequent fuel damage or compromise of the fuel storage or building configurations leading to radiological or criticality concerns. The new racks have been analyzed in their new configuration and found safe during seismic motion. The fuel stored in these racks has been determined to remain intact and the racks maintain the fuel and fixed poison configurations subsequent to a seismic event. The structural capability of the pool and liner willnot be exceeded under the appropriate combinations of dead weight, thermal, and seismic loads. The Fuel Handling Building structure willremain intact during a seismic event and will continue to adequately support and protect the fuel racks, storage array, and pool moderator/coolant. Thus, the consequences of a seismic event are not increased.

. Fuel misloading and mislocation accidents were previously credible occurrences, since fuel could be placed at an unintended storage location or could have been lowered outside and adjacent to a storage rack in Pools 'A'r

'B'. However, neither of these two scenarios previously represented any concern because of the flux trap style of the rack designs in these two pools. Similar procedures, equipment and methods of fuel movement willbe used for Pools

'C'nd

'D's those used previously for Pools 'A'nd 'B'. Therefore, the proposed activity does not represent any increase in the probability of occurrence. The proposed non-flux trap design racks for Pools 'C'nd 'D'equire administrative controls to ensure that fuel assemblies meet effective enrichment criteria prior to storage. Under these conditions, misloading of a fuel assembly by placement in an unintended storage cell has no significant consequences.

Therefore, the only remaining potential mislocation of a fuel assembly is for an assembly to be lowered outside of and directly adjacent to a storage rack. This accident occurring in Pools 'C'r 'D'as been analyzed'for the worst possible storage configuration subsequent to the proposed activity and it has been shown that the consequences remain acceptable with respect to the same criteria used previously. Thus, there is no increase in consequences for fuel mislocation or

,misloading.

Therefore it is concluded that the proposed changes do not significantly increase the probability or consequences of any accident previously evaluated.

Create the possibility of a new or different kind of accident from any previously analyzed.

To assess the possibility of new or different kind of accidents, a list of the important parameters required to ensure safe fuel storage was established.

Safe fuel storage is defined here as providing an environment, which would not present any significant threats to workers or the general public (i.e., meeting the requirements of 10CFR100 and 10CFR20). Any new events, which would modify these parameters sufficiently to place them outside of the boundaries analyzed for normal conditions and/or outside of the boundaries previously considered for accidents would be considered to create the possibility of a new or different accident. The criticality and radiological safety evaluations were reviewed to establish the list of important parameters.

The fuel configuration and the existence of the moderator/coolant were identified as the only two parameters, which were important to safe fuel storage. Significant modification of these two parameters represents the only possibility of an unsafe storage condition. Once the two important parameters were established, an additional step was taken to determine what events (which were not previously

'considered) could result in changes to the storage configuration or moderator/coolant presence during or subsequent to the proposed changes.

This process was adopted to ensure that the possibility of any new or different accident scenario or event would be identified. Due to the proposed activity, an accidental drop of a rack module during construction activity in the pool was considered as the only event which might represent a new or different kind of accident. '

construction accident resulting in a rack drop is an unlikely event. The proposed activity willutilize the defense-in-depth approach for these heavy loads. The defense-in-depth approach is intended to meet the requirements of NUREG-0612 and preclude the possibility of a rack drop. Allmovements of heavy loads over the pool willcomply with the applicable administrative controls and guidelines'i.e. plant procedures, NUREG-0612, etc.). A temporary hoist and rack lifting rig willbe introduced to liftand suspend the racks from the bridge of the AuxiliaryCrane. These items have been designed in accordance with the requirements of NUREG-0612 and ANSI N14.6 and willbe similar to those used recently to install storage rack modules in Pool 'B'.

The postulated rack drop event is commonly referred to as a "heavy load drop" over the pools. Heavy loads willnot be allowed to travel over any racks containing fuel assemblies.

The danger represented by this event is that the racks willdrop to the pool floor and the pool structure willbe compromised leading to loss of moderator/coolant, which is one of the two important parameters identified above. Although the analysis of this event has been performed and shown to be acceptable, the question of a new or different type of event is answered by determining whether heavy load drops over the pool have been considered previously. As stated above, heavy loads (storage rack modules) were recently installed in Pool 'B'sing similar methods. Therefore, the rack drop does not represent a new or different kind of accident.

The proposed change does not alter the operating requirements of the plant or of the equipment credited in the mitigation of the design basis accidents. The proposed change does not affect any of the important parameters required to ensure safe fuel storage. Therefore, the potential for a new or previously unanalyzed accident is not created.

Involve a significant reduction in the margin of safety.

The function of the Spent Fuel Pool is to store the fuel assemblies in a subcritical and coo!able configuration through ail environmental and abnormal loadings, such as an earthquake or fuel assembly drop. The new rack design must meet ail applicable requirements for safe storage and be functionally compatible with Pools 'C'nd 'D'.

CPB L has addressed the safety issues related to the expanded pool storage capacity in the following areas:

1.

Material, mechanical and structural considerations

The mechanical, material, and structural designs of the new racks have been reviewed in accordance with the applicable provisions of the NRC Guidance entitled, "Review and Acceptance of Spent Fuel Storage and Handling Applications". The rack materials used are compatible with the spent fuel assemblies and the Spent Fuel Pool environment. The design of the new racks preserves the proper margin of safety during normal and abnormal loads. It has been shown that such loads willnot invalidate the mechanical design and material selection to safely store fuel in a eoolable and subcritical configuration.

Nuclear criticality The methodology used in the cnticaiity analysis of the expanded Spent Fuel Pool meets the appropriate NRC guidelines and the ANSI standards (GDC 62, NUREG 0800, Section 9.1.2, the OT Position for Review and Acceptance of Spent Fuel Storage and Handling Applications, Reg. Guide 1.13, and ANSI/ANS 8.17). The margin of safety for subcriticality is maintained by having the neutron multiplication factor equal to, or less than, 0.95 under all accident conditions, including uncertainties. This criterion is the same as that used previously to establish criticality safety evaluation acceptance and remains satisfied for all analyzed accidents.

3.

Thermal-hydraulic and pool cooling The thermal-hydraulic and cooling evaluation of the pools demonstrated that the pools can be maintained below the specified thermal limits under the conditions of the maximum heat load and during all credible accident sequences and seismic events. The pool temperature willnot exceed 137'F during the highest heat load conditions. The maximum local water temperature in the hot channel willremain below the boiling point. The fuel will not undergo any significant heat up after an accidental drop of a fuel assembly on top of the rack blocking the flow path. A loss of cooling to the pool willallow sufficient time (>13 hours) for the operators to intervene and line up alternate cooling paths and the means of inventory make-up before the onset of pool boiling. The thermal limits specified for the evaluations performed to support the proposed activity are the same as those that were used in the previous evaluations.

It has also been demonstrated that adequate margin exists in the Unit 1 CCW system to support near term operation of the pools subject to the requirements of the proposed changes to the Technical Specifications.

Based on the preceding discussion it is concluded that this activity does not involve a significant reduction in the margin of safety.

0 c

I The NRC staff has reviewed the licensee's analysis and, based on this review, it appears that the three standards of 10 CFR 50.92(c) are satisfied. Therefore, the NRC staff proposes to determine that the amendment request involves no significant hazards consideration.

The Commission is seeking public comments on this proposed determination.

Any comments received within 30 days after the date of publication of this notice willbe considered in making any final determination.

Normally, the Commission willnot issue the amendment until the expiration of the 30-day notice period.

However, should circumstances change during the notice period such that failure to act in a timely way would result, for example, in derating or shutdown of the facility, the Commission may issue the license amendment before the expiration of the 30-day notice period, provided that its final determination is that the amendment involves no significant hazards consideration.

The final determination willconsider all public and State comments received.

Should the Commission take this action, it willpublish in the FEDERAL REGISTER a notice of issuance and provide for opportunity for a hearing after issuance.

The Commission expects that the need to take this action willoccur very infrequently.

Written comments may be submitted by mail to the Chief, Rules and Directives Branch, Division of Administrative Services, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, and should cite the publication date and page number of this FEDERAL REGISTER notice. Written comments may also be delivered to Room 6D59, Two White Flint North, 11545 Rockville Pike, Rockville, Maryland, from 7:30 a.m.

to 4:15 p.m. Federal workdays. Copies of written comments received may be examined at the NRC Public Document Room, the Geiman Building, 2120 L Street, NW., Washington, DC.

The filingof requests for hearing and petitions for leave to intervene is discussed below.

By February 12, 1999, the licensee may file a request for a hearing with respect to issuance of the amendment to the subject facilityoperating license and any person whose interest may be affected by this proceeding and who wishes to participate as a party in the proceeding must file a written request for a hearing and a petition for leave to intervene.

Requests for a hearing and a petition for leave to intervene shall be filed in accordance with the Commission's "Rules of Practice for Domestic Licensing Proceedings" in 10 CFR Part 2.

interested persons should consult a current copy of 10 CFR 2.714 which is available at the Commission's Public Document Room, the Gelman Building, 2120 L Street, NW., Washington, DC, and at the local public document room located at the Cameron Village Regional Library, 1930 Clark Avenue, Raleigh, No'rth Carolina 27605.

If a request for a hearing or petition for

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leave to intervene is filed by the above date, the Commission or an Atomic Safety and Licensing Board, designated by the Commission or by the Chairman of the Atomic Safety and Licensing Board Panel, willrule on the request and/or petition; and the Secretary or the designated Atomic Safety and Licensing Board willissue a notice of hearing or an appropriate order.

As required by 10 CFR 2.714, a petition for leave to intervene shall set forth with particularity the interest of the petitioner in the proceeding, and how that interest may be affected by the results of the proceeding.

The petition should specifically explain the reasons why intervention should be permitted with particular reference to the following factors:

(1) the nature of the petitionefs right under the Act to be made party to the proceeding; (2) the nature and extent of the petitioner's property, financial, or other interest in the proceeding; and (3) the possible effect of any order which may be entered in the proceeding on the petitioner's interest. The petition should also identify the specific aspect(s) of the subject matter of the proceeding as to which petitioner wishes to intervene.

Any person who has filed a petition for leave to intervene or who has been admitted as a party may amend the petition without requesting leave of the Board up to 15 days prior to the first prehearing conference scheduled in the proceeding, but such an amended petition must satisfy the specificity requirements described above.

I Not later than 15 days prior to the first prehearing conference scheduled in the proceeding, a petitioner shall file a supplement to the petition to intervene which must include a list of the contentions which are sought to be litigated in the matter.

Each contention must consist of a specific statement of the issue of law or fact to be raised or controverted.

ln addition, the petitioner shall provide a brief explanation of the bases of the contention and a concise statement of the alleged facts or expert opinion which support the contention and on which the petitioner intends to rely in proving the contention at the hearing. The petitioner must also provide references to those specific sources and documents of which the petitioner is aware and on which the petitioner intends to rely to establish those facts or expert opinion.

Petitioner must provide sufficient information to show that a genuine dispute exists with the applicant on a material issue of law or fact. Contentions shall be limited to matters within the scope of the amendment under consideration.

The contention must be one which, if proven, would entitle the petitioner to relief. A petitioner who fails to file such a supplement which satisfies these requirements with respect to at least one contention willnot be permitted to participate as a party.

Those permitted to intervene become parties to the proceeding, subject to any limitations in the order granting leave to intervene, and have the opportunity to participate fully

in the conduct of the hearing, including the opportunity to present evidence and cross-examine witnesses.

If a hearing is requested, the Commission willmake a final determination on the issue of no significant hazards consideration.

The final determination willserve to decide when the hearing is held.

Ifthe final determination is that the amendment request involves no significant hazards consideration, the Commission may issue the amendment and make it immediately effective, notwithstanding the request for a hearing. Any hearing held would take place after issuance of the amendment.

lfthe final determination is that the amendment request involves a significant hazards consideration, any hearing held would take place before the issuance of any amendment.

A request for a hearing or a petition for leave to intervene must be filed with the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, Attention: Rulemakings and Adjudications Staff, or may be delivered to the Commission's Public Document Room, the Gelman Building, 2120 L Street, NW., Washington, DC, by the above date.

A copy of the petition should also be sent to the Office of the General Counsel, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, and to William D. Johnson, Vice President and Senior Counsel, Carolina Power 8 Light Company, Post Office Box 1551, Raleigh, North Carolina 27602, attorney for the licensee.

Nontimely filings of petitions for leave to intervene, amended petitions, supplemental petitions and/or requests for hearing willnot be entertained absent a determination by the Commission, the presiding officer or the presiding Atomic Safety and Licensing Board that the petition and/or request should be granted based upon a balancing of the factors specified in 10 CFR 2.714(a)(1)(i)-(v) and 2.714(d).

~ 12 The Commission hereby provides such notice that this is a proceeding on an application for a license amendment falling within the scope of section 134 of the Nuclear Waste Policy Act of 1982 (NWPA), 42 U.S.C. 10154.

Under section 134 of the NWPA, the Commission, at the request of any party to the proceeding, must use hybrid hearing procedures with respect to "any matter which the Commission determines to be in controversy among the parties."

The hybrid procedures in section 134 provide for oral argument on matters in controversy, preceded by discovery under the Commission's rules and the designation, following argument of only those factual issues that involve a genuine and substantial dispute, together with any remaining questions of law, to be resolved in an adjudicatory hearing.

Actual adjudicatory hearings are to be held on only those issues found to meet the criteria of section 134 and set for hearing after oral argument.

The Commission's rules implementing section 134 of the NWPA are found in 10 CFR Part 2, Subpart K, "Hybrid Hearing Procedures for Expansion of Spent Fuel Storage Capacity at Civilian Nuclear Power Reactors" (published at 50 FR 41662 dated October 15, 1985).

Under those rules, any party to the proceeding may invoke the hybrid hearing procedures by filingwith the presiding officer a written request for oral argument under 10 CFR 2.1109.

To be timely, the request must be filed within ten (10) days of an order granting a request for hearing or petition to intervene. The presiding officer must grant a timely request for oral argument.

The presiding officer may grant an untimely request for oral argument only upon a showing of good cause by the requesting party for the failure to file on time and after providing the other parties an opportunity to respond to the untimely request.

lfthe presiding officer grants a request for oral argument, any hearing held on the application must be conducted in accordance with the hybrid hearing procedures.

ln essence, those procedures limitthe time available for discovery and require that an oral argument be held to determine whether any contentions must be resolved in an adjudicatory hearing.

Ifno party to the proceeding timely requests oral argument, and ifall untimely requests for oral argument are denied, then the usual procedures in 10 CFR Part 2, Subpart G apply For further details with respect to this action, see the application for amendment dated I

December 23, 1998, which is available for public inspection at the Commission's Public 1

Document Room, the Gelman Building, 2120 L Street, NW., Washington, DC, and at the local public document room located at the Cameron Village Regional Library, 1930 Clark Avenue, Raleigh, North Carolina 27605.

Dated at Rockville, Maryland, this 7th day of January 1999.

FOR THE NUCLEAR REGULATORYCOMMISSION OIiginal signed by Scott Flanders, Project Manager Project Directorate II-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket No. 50-400 Distribution:

Docket File PD II-3 Rdg OGC G:>HARRISVind w d OFFICE NAME DATE COPY PM:

SFI 1/7/99 Yes/No LA:PDII-2 EDunnln on 1/

/99 es/

o D:PDIID c

s 1/

/99 Y

No

4 Kl I