ML18017A924

Provides Supplemental Info Re 981223 Lar,Placing Plant Spent Fuel Pools 'C' & 'D' in Service.Info Provided Does Not Change Util Initial Determination That Proposed License Amend Represents No Significant Hazards Consideration

ML18017A924
Person / Time
Site:	Harris
Issue date:	10/15/1999
From:	Alexander D CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HNP-99-156, NUDOCS 9910270013
Download: ML18017A924 (7)

Text

ATEGORY j.

REGULATORY INFORMATXON DISTRIBUTIO SYSTEM (RIDS)

ACCESSION NBR:9910270013 DOC.DATE: 99/10/15 NOTARIZED: NO DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH.NA'lE , AUTHOR AFFILIATION ALEXANDER,D;B. Carolina Power 6 Light Co.

RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)

SUBJECT:

Provides supplemental infor re 981223 LAR,placing plant spent fuel pools 'C' 'D'n service. Info provided does not change util initial determination that proposed license amend represents no signficant hazards consideration.

DISTRIBUTION CODE: AOOID COPIES RECEIVED:LTR i ENCL i S1EE:

TITLE: OR Submittal: General Distribution E

NOTES:Application for permit renewal filed. 05000400 RECXPIENT COPIES RECIPIENT COPIES XD CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL DUNNINGTON,E 1 1 LAUFER,R. 1 1 SC 1 1 INTERNAL: ACRS 1 1 .1 NRR/DSSA/SPLB 1 1 1 1 NUDOCS-ABSTRACT 1 1 OGC/RP 1 0 EXTERNAL: NOAC 1 1 NRC PDR 1 1 D

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NOTE TO ALL "RZDS" RECIPIENTS 1 PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT LISTS THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OP COPIES REQUIRED: LTTR 11 ENCL 10

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OCT 15 1999 Carolina Power 8 Light Company Harris Nuclear Plant SERIAL: HNP-99-156 PO Box 165 New Hill NC 27562 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 SUPPLEMENTAL INFORMATIONREGARDING THE LICENSE AMENDMENTREQUEST TO PLACE HNP SPENT FUEL POOLS 'C'ND 'D'N SERVICE

Dear Sir or Madam:

Enclosure 8 of the HNP license amendment request (ref. SERIAL: HNP-98-188, dated December 23, 1998) provided a detailed Alternative Plan for demonstrating compliance with ASME Boiler

& Pressure Vessel Code requirements for spent fuel pool cooling and cleanup system piping in accordance with 10 CFR 50.55a(a)(3)(i). By letter dated March 24, 1999, the NRC issued a request for additional information (RAI) related to the Harris Nuclear Plant (HNP) license amendment request to place spent fuel pools C and D in service. The March 24, 1999 RAI included a request to identify each of the embedded field welds within the scope of the Alternative Plan. The HNP response (ref. SERIAL: HNP-99-069, dated April 30, 1999) provided a field weld matrix which identified the field welds to be inspected by using a high resolution remote video camera. The sample size was selected based on a feasibility walkdown with the camera vendor. CP&L has continued, however, to investigate alternative inspection methods with other vendors. Through these efforts with another vendor, CP&L has successfully performed a remote camera inspection of all 15 embedded field welds included within the scope of the Alternative Plan. In the course of the inspection, two field welds (2-SF-1-FW-3 and 2-SF-1-FW-6) which were not embedded in concrete, but within the scope of the Alternative Plan, were cut out to facilitate removal of piping to provide access for the camera inspections. An updated field weld matrix will be provided to reflect the removal of these two welds and the inspection of all 15 embedded field welds.

In addition, by letter dated April 29, 1999, the NRC issued an RAI related to the criticality control provisions in the HNP license amendment request. Item 1 of this RAI requested information regarding a postulated fresh fuel assembly misloading event. As a supplement to our June 14, 1999 response (ref. SERIAL: HNP-99-094) to requested item 1 of the RAI, we had our vendor, Holtec International, perform additional fuel assembly misloading analyses. The results of these analyses are included as an Enclosure to this letter. These analyses demonstrate that criticality willnot occur as a result.~f- thy postulated misloading of a fresh fuel assembly in the spent fuel storage racks for H6Q Qbois 5 and D.

99i02700i3 99iOi5 05000400 Harris Road New Hill NC PDR ADGCK P , PDR

Document Control Desk SERIAL: HNP-99-156 Page 2 This information is provided as a supplement to our December 23, 1998 license amendment request and does not change our initial determination that the proposed license amendment represents a no significant hazards consideration.

Please refer any questions regarding the enclosed information to Mr. Steven Edwards at (919) 362-2498.

Sincerely,

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Donna B. Alexander Manager, Regulatory Affairs Harris Nuclear Plant KWS/kws

Enclosure:

(all w/ Enclosure)

Mr. J. B. Brady, NRC Senior Resident Inspector Mr. Mel Fry, N.C. DEHNR Mr. R. J. Laufer, NRC Project Manager Mr. L. A. Reyes, NRC Regional Administrator - Region II

Document Control Desk SERIAL: HNP-99-156 Page 3 bc: (all w/Enclosure)

Mr. K. B. Altman Ms. L. N. Hartz Mr. G. E. Attarian Mr. W J. Hindman Mr. R. H. Bazemore Mr. C. S. Hinnant Mr. C. L. Burton Mr. W. D. Johnson Mr. S. R. Carr Mr. G. J. Kline Mr. J. R. Caves Mr. B. A, Kruse Mr. H. K. Chernoff (RNP) Ms. T. A. Head (PEARAS File)

Mr. B. H. Clark Mr. R. D. Martin Mr. W. F. Conway Mr. T. C. Morton Mr. G. W. Davis Mr. J. H. O'eill, Jr.

Mr. M. J. Devoe Mr. J. S. Scarola Mr. W. J. Dorman (BNP) Mr. J. M. Taylor Mr. R. S. Edwards Nuclear Records Mr. R. J. Field Harris Licensing File Mr. K. N. Harris Files: H-X-0511 H-X-0642

55555 Holtec Center, 555 Lincoln Drive West, Marlton, NJ 08053 Telephone (609) 797-0900 Fax (609) 797-0909 October 11, 1999 Mr. Steven Edwards Manager of Projects Carolina Power &, Light Company Harris Nuclear Plant P.O. Box 165 New Hill, NC 27562

References:

Holtec Project 70324 CP &L Contract XTA7000024

Subject:

Additional Criticality Analysis Results

Dear Mr. Edwards,

Per your request, and in support of the recent NRC RAIs pertaining to the criticality evaluations performed for fuel storage in pools C and D, we have performed additional analyses.

RAI ¹1 from the NRC stated that an evaluation of a fuel assembly misloading event should be analyzed. Holtec's previous response drew upon earlier spent fuel rack evaluations and stated that the k,fr would remain below 0.95 with a minimum of 400 ppm soluble boron in the pool.

As a supplement to this response, Holtec International has performed additional analyses for the Harris Spent Fuel Pools C and D to determine the amount of soluble boronxequired to maintain k;fbelow 0.95 with a misloaded fresh PWR fuel assembly. The results of this analysis are summarized here.

The inadvertent misloading of a fresh PWR fuel assembly into Harris Pools C and D was analyzed using MCNP-4A and CASMO-3. A delta-k;f for the misloading event was calculated using MCNP and this delta-k;r was applied to the maximum k;f in the licensing amendment report (LAR) to determine the maximum k;r under the misloading scenario. This accident scenario consisted of a single 5 wt.% U PWR fresh fuel assembly misloaded into the PWR racks surrounded by fuel of maximum reactivity as determined by the burnup and enrichment curve in the LAR. The k;f for the PWR racks with the misloaded fresh assembly, without taking credit for soluble boron, was determined to be 0.9916 with a 95%/95% confidence level.

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t 5155m HOLTEC Holtec Center, 55S Lincoln Drive West, Marlton, NJ 080S3 Telephone (609) 797-0900 Fax (609) 797-0909 I N T E R N AT I 0 N AL Mr. Steven Edwards Carolina Power Ec Light Company Page 2 A second scenario was also analyzed in which the fresh 5 wt.% U PWR fuel assembly was placed in a PWR storage cell adjacent to the BWR storage racks. The PWR and BWR racks were filled with fuel of maximum permissible reactivity. The k;f for this scenario with the misloaded fresh 5 wt.% U PWR fuel assembly, without taking credit for soluble boron, was 0.9932 with a 95%/95% confidence level.

These results clearly demonstrate that the spent fuel pool will remain subcritical even with a fresh 5 wt.% U PWR fuel assembly misloaded in the PWR racks.

The April 1978 NRC letter to All Power Reactor Licensees states that "The double contingency principle of ANSI N-16.1-1975 shall be applied. It shall require two unlikely, independent, concurrent events to produce a criticality accident." Consistent with this approach, credit for soluble boron, which is normally in the spent fuel pool, was taken when the misloaded fresh 5 wt.% U PWR fuel was analyzed. It was determined that the maximum k;r for the misloading accident is 0.9352 with 400 ppm soluble boron in the spent fuel pool water. Therefore, the minimum amount of soluble boron required to maintain k;r less than the regulatory limit of 0.95 under all postulated abnormal and accident conditions is 400 ppm.

Additional calculations were also performed to determme the"k;r'for the misloading accident with 1000 and 2000 ppm soluble boron in the spent fuel pool water. The maximum k;fwas calculated to be 0.8671 and 0.7783 for the 1000 and 2000 ppm respectively. These results demonstrate that there is considerable un-credited margin in the criticality analysis of Harris Spent Fuel Pools C and D.

Ifyou have any questions please feel free to contact me.

Scott H. Pellet Project Manager cc: Holtec Engineering File 80964 Holtec Contracts file Document ID: 80964SP1