ML18106B050
| ML18106B050 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 02/02/1999 |
| From: | Storz L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18106B052 | List: |
| References | |
| LCR-S98-17, LR-N990056, NUDOCS 9902090145 | |
| Download: ML18106B050 (13) | |
Text
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. ~: Public Service Electric and Gas Company Louis F. Storz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President
- Nuclear Operations LR-N990056 LCR S98-17 United States Nuclear Regulatory Commission FEB 2 1999*
Document Control Desk Washington, DC 20555 Gentlemen:
REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS PERMISSIBLE ENRICHMENT VALUES FOR NEW FUEL STORAGE SALEM G.ENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 In accordance with the requirements of 10CFR50.90, Public Service Electric &
Gas Company (PSE&G) hereby transmits a request to revise the Technical Specifications (TS) for Salem Generating Station Unit Nos. 1 and 2 respectively.
Pursuant to the requirements of 10CFR50.91 (b)(1 ), a copy of this request has been sent to the State of New Jersey.
The proposed TS changes contained herein modify the acceptable enrichment value for new fuel storage from 4.5 to 5.0 weight percent U23 as delineated in Section 5.6.1.1 of the Technical Specifications. In addition, Section 5.6.1.2.d.3. is modified to allow the use of equivalent control to that provided by the currently specified 2.35 mg B-10/linear inch for the Integral Fuel Burnable Absorber (IFBA) pins. The first change will provide consistency with the values which are currently included in Section 5.6.1.2 of the Technical Specification for the Spent Fuel Storage Racks and the second change allows for flexibility in IFBA selection and loading, while maintaining the same requirement for overall fuel assembly reactivity. Approval of this revision request will permit higher energy core reloads thus supporting capacity factor improvements, and clarify the use of equivalent methods of assuring reactivity controls for IFBA pins. The requested change concerning the increased enrichment for new fuel storage is consistent with approved revisions at other facilities which are documented on the Reference List Enclosure 1.
The proposed changes have been evaluated in accordance with 10CFR50.91 (a)(1 ), using the criteria in 10CFR50.92(c), and PSE&G has made the determination that this request involves no significant hazards considerations.
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--*** FEB 2 1999 Document Control Desk LR-N990056 A description of the requested amendment, the reason for the changes, and the justification for the changes are provided in Attachment 1. The basis for no significant hazards consideration determination is provided in Attachment 2. The Technical Specification pages affected by the proposed changes are provided in Attachment 3. Attachment 4 includes supporting analyses for these proposed changes.
PSE&G requests a 60 day implementation period after amendment approval.
Approval of this change is requested by June 25, 1999 to permit appropriate implementation and planning.
Should you have any questions regarding this request, please contact John Nagle, Salem Licensing, at (609) 339-3171.
Sincerely,
/jcn Affidavit Attachments (5)
C Mr. H.J. Miller, Administrator - Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. P Milano, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. S. Morris (X24)
USNRC Senior Resident Inspector Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 95-4933
fFEB 2 1999 REF: LR-N990056 LCR S98-17 STATE OF NEW JERSEY)
) SS.
COUNTY OF SALEM )
L. F. Storz, being duly sworn according to law deposes and says:
I am Senior Vice President - Nuclear Operations for the Public Service Electric &
Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning the Salem Generating Station, Units Nos. 1 and 2, are true to the best of my knowledge, information and belief.
Subs.Gii.bed and Swor)Ja:forn me this ~C/fi_ day of , 1999
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Notary Public of New Jersey N DELORIS D. HADDEN
':ry Publi!! 01 New Jersey My Commission expires on _ _ _Y_Co_.o.... ~<:.c~;.o;i'9. . ,s2.o;\;1 b/f,~f-><P_ir_es_ _ _ __
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Document Control D e .
Attachment 1 LR N990056 LCR S98-17 SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR - 70 AND DRP - 75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS PERMISSIBLE ENRICHMENT VALUES FOR NEW FUEL STORAGE DESCRIPTION OF THE PROPOSED CHANGE This amendment revises the maximum permissible enrichment of stored new fuel described in the Design Features - Section 5 of the Technical Specifications as indicated below:
- 1. Specification 5.6.1.1.c is being replaced with the following:
Unirradiated fuel assemblies with enrichments less than or equal to 4.25 weight percent (w/o) U-235 with no requirements for Integral Fuel Burnable Absorber (IFBA) pins.
- 2. A new Specification 5.6.1.1.d is added as follows:
Unirradiated fuel assemblies with enrichments (E) greater than 4.25 w/o U-235 and less than or equal to 5.0 w/o U-235 which contain a minimum number of Integral Fuel Burnable Absorber (IFBA) pins. This minimum number of IFBA pins shall have an equivalent reactivity hold-down which is greater than or equal to the reactivity hold down associated with N IFBA pins, at a nominal 2.35 mg B-10/linear inch loading (1.5X), determined by the equation below:
N = 42.67 ( E - 4.25 )
- 3. Specification 5.6.1.2.d.3. is revised as shown in bold as follows:
Unirradiated fuel assemblies with enrichments (E) greater than 4.25 wlo U-235 and less than or equal to 5.0 wlo U-235 which contain a minimum number of Integral Fuel Burnable Absorber (IFBA) pins.
This minimum number of IFBA pins shall have an equivalent reactivity hold-down which is greater than or equal to the reactivity hold down associated with N IFBA pins, at a nominal 2.35 mg B-10/linear inch loading (1.5X), determined by the equation below, have unrestricted storage:
N = 42.67 ( E - 4.25 )
REASONFORTHEPROPOSEDCHANGES Page 2
. Document Control Desk Attachment 1 e
LRN990056 LCR S98-17 Presently, new fuel with a maximum enrichment of 4.5 weight percent (w/o) U235 can be stored in the New Fuel Storage Vault. The revised Technical Specifications will permit the New Fuel Storage Vault to store unirradiated fuel with a maximum enrichment of 5.0 wlo U235 . Storage and use of fuel with higher enrichment supports PSE&G's goals to achieve higher energy core reloads which can contribute substantially to improved capacity factors.
The storage of fuel with IFBA pins in the new fuel or spent fuel racks with equivalent burnable absorber loading to the specified 8-10 loading allows the storage of overall lower loading of 8-10 in order to provide additional rod internal pressure margin ta* compensate for the helium release from IFBA pins and associated fuel performance issues (NRC IN 98-29 "Predicted Increase in Fuel Rod Cladding Oxidation")
JUSTIFICATION FOR THE PROPOSED CHANGES The Criticality Analysis (Attachment 4) demonstrates that fuel assemblies with enrichments less than or equal to 4.65 w/o U235 can be stored in the New Fuel Vault without Integral Fuel Burnable Absorber (IFBA) pins while maintaining adequate sub-critical margin as given in the NRC acceptance criteria. Fuel assemblies with enrichments (E) greater than 4.65 (but less than or equal to 5.0) w/o U235 , must contain a number of IFBA pins (with an equivalent nominal 2.35 mg 81 O/linear inch loading) which is equal to or greater than the number (N), determined by the following equation (Attachment 4, Figure 4):
N =45. 71 (E - 4.65) Eqn. 1 However, IFBA pin number values derived from this equation, though acceptable from a criticality analysis standpoint, are inconsistent with and less conservative than the approved re~uirement for unrestricted Spent Fuel Pool storage of up to 5.0 w/o U23 fuel, as described in Attachment 8 to LCR 93-02, TS Section 5.6.1.2.d.3. (Ref.: Amendments 151/131 - Units 1 & 2 respectively).
Amendments 151/131 to the facility operating license established a requirement for unrestricted storage of fuel assem.blies in the Spent Fuel pool. For fuel with enrichments greater than 4.25 w/o U235 (but less than or equal to 5.0 wlo U235 ) to be freely placed in any storage position (e.g.
unrestricted storage) the fuel must contain a number of IFBA pins (with a nominal 2.35 mg 81 O/linear inch loading) which is equal to or greater than the number (N), determined by the following equation:
N =42.67 (E - 4.25) Eqn. 2 Attachment 1 Page 3
Document Control Desk Attachment 1 e
LRN990056 LCR S98-17 Equation 2 will be included in the amended Technical Specifications for the New Fuel Storage Vault. This will ensure consistency between the new and spent fuel storage locations and preclude the possibility of having new fuel assemblies which would not satisfy the requirements for unrestricted storage in the Spent Fuel Pool.
Boron (B-10) is the most commonly used burnable absorber, however it is not the only available product for this purpose, thus it is appropriate to allow different loading in so far as they provide equivalent levels of reactivity hold down.
Hence, this Technical Specification change is justified for the following reasons:
- 1. The analyses cited in support of this change rely on conservative assumptions.
- 2. From a bundle reactivity standpoint, 5.0 w/o enriched fuel in the new fuel storage vault, with the designated IFBA pins, is equivalent to 4.65 w/o enriched fuel without IFBA pins. The new analysis supports storage of 4.65 w/o enriched fuel without IFBA pins, however for consistency, the more conservative limit of 4.25 w/o for the spent fuel pool will be utilized.
3: The analytically-derived results satisfy the NRC acceptance criteria (at 95/95 probability/confidence, including uncertainties) with respect to reactivity values which maintain adequate margin below criticality for all analyzed events.
- 4. The Technical Specification changes are consistent with the analyses and technical justifications provided in support of the change.
- 5. Specifying burnable absorber level in terms of equivalent values to 8-10 continues to provide the same level of reactivity hold down. Page 4
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LR N990056 LCR S98-17 SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR - 70 AND DRP - 75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS PERMISSIBLE ENRICHMENT VALUES FOR NEW FUEL STORAGE DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION Pursuant to 10CFR50.92, PSE&G reviewed the proposed revision to determine whether our request involves a significant hazards consideration. PSE&G has determined that operation of Salem Generating Station, Unit Nos. 1 and 2, in accordance with the proposed changes:
- 1. Will not involve a significant increase in the probability or consequences of an accident previously evaluated.
a) Fuel Assembly Drop There is no increase in the probability of a fuel assembly drop accident because the mass of a fuel assembly does not increase when the fuel enrichment is increased. This amendment affects only the isotopic composition within the fuel pellets of a fuel assembly without involving any changes to the outward physical characteristics or structural integrity of the assembly.
The radiological consequences of a new fuel assembly drop accident do not increase as a consequence of the proposed change to new fuel enrichment. Because it has not been irradiated, there are no significant radiological consequences associated with fresh fuel. The radiological consequences of an irradiated fuel assembly drop were previously evaluated and approved in the Spent Fuel license amendment numbers 151/131, (Units 1 & 2 respectively.)
b) Misplaced Fuel Assembly in New Fuel Storage Vault or Spent Fuel Storage Racks There is no increase in the probability of a misplaced fuel assembly in the New Fuel Storage Vault or Spent Fuel Storage Racks. The proposed change does not alter the physical structure of the New Fuel Storage.Vault or the Spent Fuel Storage Racks. All new fuel assembly movements will continue to be made in accordance with approved procedures.
There is no increase in the consequences of misplacing a fuel assembly in the new fuel storage racks. The normally-dry new fuel vault Kett is very small (approximately 0.65), as such, there is sufficient reactivity margin to the 0.95 limit to bound any possible misplacement. Page 1
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LRN990056 LCR S98-17 The double contingency principle does not require consideration of a second unlikely event. Since a misplaced bundle constitutes the first unlikely event, presence of moderator in the normally dry new fuel storage racks (a second unlikely event) is not assumed in evaluating the event.
The inadvertent misplacement of a fresh fuel assembly in the spent fuel storage racks has the potential for exceeding the limiting reactivity, should there be a concurrent and independent accident condition resulting in the loss of all soluble boron. Administrative procedures to assure the presence of soluble boron during fuel handling operations will preclude the possibility of the simultaneous occurrence of the two independen.t accident conditions. The analyses supporting Amendments 151/131 demonstrated that 600 ppm of soluble boron is adequate to compensate for a mis-loaded fuel event, while plant procedures require the concentration to b.e maintained at least 2300 ppm. The proposed change to allow reduced IF8A 8-10 loading does not invalidate these prior analyses since equivalent reactivity hold down to the 2.35 mg/linear inch 8-10 loading will be maintained.
c) Introduction of Moderator to the New Fuel Vault There is no increase in the probability of any accident involving moderator introduction to the new fuel storage vault. The proposed change affects only the enrichment within the fuel assemblies. No other plant systems or components are affected by this change.
There is no increase in the consequences of introducing a moderator to the new fuel storage vault resulting from increased fuel enrichment. The new fuel storage vault has been analyzed for storage of fuel assemblies with nominal enrichments of 4.65 w/o U235 at the fully flooded condition and 5.00 w/o U235 at the optimum moderation condition, as described in the attached Criticality Analysis (Attachment 2). As long as the requirement for the number of IF8A pins versus assembly enrichment is met, calculated Kett (including uncertainties and biases) does not exceed 0.95 under full density conditions and does not exceed 0.98 under optimum moderation conditions.
These analyses demonstrate that 5.0 w/o enrichment fuel storage in the New Fuel Storage Vault complies with criticality acceptance criteria for all moderation conditions. Therefore, based on the conclusions of the above analyses, the proposed changes will not involve a significant increase in the probability or consequences of an accident previously evaluated. Page 2
Document Control Desk Attaclunent 2 e
LRN990056 LCRS98-17
- 2. Do not create the possibility of a new or different kind of accident from any accident previously analyzed.
The proposed Technical specification changes do not involve any physical changes to the plant or any changes to the method in which the plant is operated. No physical changes to the new fuel or spent fuel storage racks are required, nor any changes in the process or procedures to place fuel in the racks. The enrichment limits and reactivity hold-down requirements ensure that the assumptions used in the criticality analyses remain bounding. As such, these changes do not affect the performance or qualification of safety-related equipment.
Therefore, the possibility of a new or different type of accident than previously considered in not created.
- 3. Do not involve a significant reduction in a margin of safety.
The new fuel storage vault has been analyzed for storage of fuel assemblies with nominal enrichments of 4.65 wlo U235 at the fully flooded condition and 5.00 wlo U235 at the optimum moderation condition, as described in the attached Criticality Analysis (Attachment 2). As long as the requirement for the number of IFBA pins versus assembly enrichment in Equation 1 is met, calculated Kerr (including uncertainties and biases) does not exceed 0. 95 under full density conditions and does not exceed 0.98 under optimum moderation conditions.
For the 5.00 wlo U235 enrichment requested, Equation 2, which bounds Equation 1, will be used in the Technical Specifications related to new fuel storage.
Therefore, since the calculated values of Ken have been shown to be below the regulatory limits (including uncertainties and biases) and because they reflect a substantial subcritical configuration under adverse conditions, the proposed changes will not result in a significant reduction in the plant's margin of safety.
Previous analyses provided in support of Amendments 1511131 demonstrate that the addition of new fuel having IFBA pins with a loading of 2.35 mg B-10 per linear inch to the spent fuel racks does not result in a reduction in the margin of safety. Thus, providing for reactivity hold down for IFBA pins which is equivalent to a nominal 2.35 mg 8-1 O/linear inch loading in fresh fuel in the spent fuel storage racks maintains the current margin of safety.
CONCLUSION Based on the preceding discussion, PSE&G has concluded that the proposed changes to the Technical Specifications do not involve a significant hazards consideration insofar as the Attaclunent 2 Page 3
Document Control Desk Attachment 2 e
LRN990056 LCR S98-17 changes: (i) do not involve a significant increase in the probability or consequences of an accident previously evaluated, (ii) do not create the possibility of a new or different kind of accident from any accident previously evaluated, and (iii) do not involve a significant reduction in a margin of safety. Page 4
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Attachment ~
LR N990056 LCR 898-17 SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES DPR - 70 AND DRP - 75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS PERMISSIBLE ENRICHMENT VALUES FOR NEW FUEL STORAGE TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES The following Technical Specifications for Facility Operating License DPR-70 are affected by this change request:
Technical Specification 5.6.1.1 c. 5-5 5.6.1.1 d. 5-5 5.6.1.2.d.3. 5-5 The following Technical Specifications for Facility Operating License DPR-75 are affected by this change request:
Technical Specification 5.6.1.1 C. 5-5 5.6.1.1 d. 5-5 5.6.1.2.d.3 5-6 Insert the following as indicated on the attached marked-up pages.
Insert 1
- c. Unirradiated fuel assemblies with enrichments less than or equal to 4.25 weight percent (w/o) U-235 with no requirements for Integral Fuel Burnable Absorber (IFBA) pins.
Insert 2
- d. Unirradiated fuel assemblies with enrichments (E) greater than 4.25 w/o U-235 and less than or equal to 5.0 w/o U-235 which contain a minimum number of Integral Fuel Burnable Absorber (IFBA) pins. This minimum number of IFBA pins shall have an equivalent reactivity hold-down which is greater than or equal to the reactivity hold down associated with N IFBA pins, at a nominal 2.35 mg B-10/linear inch loading (1.5X), determined by the equation below:
N = 42.67 ( E - 4.25 )
Page 1 of 5
Document Control Desk Attachment 3 e
LRN990056 LCR S98-17 Insert 3
... which contain a minimum number of Integral Fuel Burnable Absorber (IFBA) pins have unrestricted storage. This minimum number of IFBA pins shall have an equivalent reactivity hold-down which is greater than or equal to the reactivity hold down associated with N IFBA pins, at a nominal 2.35 mg 8-10/linear inch loading (1.5X), determined by the equation below:
N = 42.67 ( E - 4.25 )
Page 2 of 5 Page 6
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Document Control Desft Enclosure 1 LR N990056 LCR S98-17 Reference List Plants which have received license amendment approvals to store 5.0 w/o U235 enriched fuel in the New Fuel Storage Vault:
Utilitl:'./Plant Docket# Amendment Dated Northern States Power Company Praire Island Generating Station Unit 1 50-282 108 9/3/98 Unit 2 50-306 101 9/3/98 Centerior Energy Davis-Besse Nuclear Power Station Unit 1 50-346 181 11/19/93 Texas Utilities Comanche Peak Steam Electric Station Unit 1 50-455 27 9/13/94 Unit 2 50-446 13 9/13/94 South Carolina Electric and Gas V. C. Summer Nuclear Station Unit 1 50-395 116 8/23/94 Union Electric Company Callaway Plant Unit 1 50-483 109 4/30/96