ML20101N771

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Forwards Ltr from Constituent Me Marucci,Informing That NRC Denied Request for Hearing Re Proposed Design/Configuration Change at Facility.Requests Investigation of Issues Related to Mgt of Spent Fuel Pools in Proposed Plan
ML20101N771
Person / Time
Site: Millstone Dominion icon.png
Issue date: 06/10/1992
From: Lieberman J
SENATE
To: Taylor J
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20101N649 List:
References
NUDOCS 9207100134
Download: ML20101N771 (1)


Text

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4 JOSEPH I. LitBERMAN 7407dg, IDWD .3021234-4049 tf AT8 orect CDunW"ttt tuv*oNutNT Amo oustic Woms om em== em *wa GovtaNutNTal MF ORS SM*AL evsimiss

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June 10, 1992 Mr. James M. Taylor Executive Director of Operations Nuclear Regulatory Con 1 mission Washington, DC 20555 c

Dear Mr. Taylor Enclosed is a copy of a letter from one of my constituents, Mary Ellen Marucci, who informs me that her recent request to the NRC for a public hearing concerning a proposed design / configuration change at Millstone 2 was denied. According to my constituent, a license has been granted to Northeast Utillties to move forward with its plan to use the pool at Milletone II for a full core download.

Ms. Marucci.ie very concerned that there are dangers involved in this procedure. The attached letter sets forth in detail her concerns.

Ms. Marucci la requesting an investigation of all issues related to the managen.ent of opent fuel pools in the proposed plan. She is requesting a hearing on these issues prior to use of the pool for the full coro download. I would appreciate it if you would give this request your full consideration.

Incerely,

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[pavo ,'o, UNITED STATES y .c q h NUCLEAR REGULATORY COMMISSION l W ASWNG TON. D. C. 20555

\, ,/ June 4, 1992 Docket No. 50-336 Mr. John F. Opeka Executive Vice President, Nuclear Connecticut Yankee Atomic Power Company Northeast Nuclear Energy Company Post Office Box 270 Hartford, Connecticut 06141-0270

Dear Mr. Opeka:

SUBJECT:

ISSUANCE OF AMENDMENT (TAC NO. MS3180)

The Commission has issued the enclosed Amendment No.158 to facility Operating License No. DPR-65 for Millstone Nuclear Power Station, Unit No. 2, in response to your application dated April 16, 1991, supplemented by letter dated May 7, 1992.

The amendment changes the Millstone Unit No. 2 Technical Specifications by modifying the existing two region spent fuel pool design, modified by Amendment 109, dated January 15, 1986, and Amendment 128, dated March 31, 1988, to a three region configuration.

A copy of the related Safety Evaluation is also enclosed. The notice of issuance will be included in the Commission's biweekly Federal Reaister notice.

Sincerely, Guy '. Vissing, Sent Project Manager Project Directorate I-4 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Enclosures:

1. Amendment No.158 to OPR-65
2. Safety Evaluation cc w/ enclosures:

See next page

&1 6llC / .' 2 ff~

o Mr. John F. Opeka Millstone Nuclear Power Station Northeast Nuclear Energy Company Unit 2 cc:

Gerald Garfield, Esquire R. M. Kacich, Director Day, Berry and Howard Nuclear Licensing Counselors at Law Northeast Utilities Service Company City Place Post Office Box 7.70 Hartford, Connecticut 06103-3409 Hartford, Connecticut 06141-0270 W. D. Romberg, Vice President D. O. Nr Nuist Nuclear, Operations Services Dire ' of Quality Services Northeast Utilities Service Company Nortne.st Utilities Service Company Post Office Box 270 Post Office Box 270 Hartford, Connecticut 06141-0270 Hartford, Connecticut 06141-0270 Kevin McCarthy, Director Regional Administrator

, Radiation Control Unit Region I Department of Environmental Protection U.S. Nuclear Regulatory Commission State Office Building 475 Allendale Road Hartford, Connecticut 06106 King of Prussia, Pennsylvania 19406 Bradford S. Chase, Under Sacretary First Selectmen Energy Division Town of Waterford Office of Policy and Management Hall of Records 80 Washington Street 200 Boston Post Road Hartford, Connecticut 06106 Waterford, Connecticut 06385 S. E. Scace, Nuclear Station Director W. J. Raymond, Resident Inspector Millstone Nuclear Power Station Millstone Nuclear Power Station

. Northeast Nuclear Energy Company c/o U.S. Nuclear Regulatory Comission Post Office Box 128 Post Office Box 376 Waterford, Connecticut 06385 Waterford, Connecticut 06385-0376 J. S. Keenan, Nuclear Unit Diractor Charles Brinkman, Manager Millstone Unit No. 2 Washington Nuclear Operations Northeast Nuclear Energy Company ABB Combustion Engineering Post Office Box 128 Nuclear Power Waterford, Connecticut 06385 12300 Twinbrook Pkwy, Suite 330 Rockville, Maryland 20852 Nicholas S. Reynolds Winston & Strawn 1400 L Street, NW Washington, DC 20005-3502

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D, C 20555 k...../

@RTHEAST NUCLEAR ENERGY COMPANY THE CONNECTICUT LIGHT AND POWER COMPANY THE WESTERN MASSACHUSETTS ELECTRIC COMPANY QQ(KET NO. 50-336 MILLSTONE NUCLEAR POWER STATION. UNIT NO. 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No.158 License No. OPR-65

1. The Nuclear Regulatory Comission (the Comission) has found that:

A. Thc application for amendment by Northeast Nuclear Energy Company, et al. (the licensee) dated April 16, 1992, supplemented by letter dated May 7,1992, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended-(the Act), and the J

Comission's rules and regulations set forth. in 10 CFR Chapter I; B. The_ facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the-Comission; C. There-is reasonable assurance (1) that the activities authorized by this amendment can be conducted without endangering.the health and safety of the public, and (ii) that such activities will be conducted-in compliance with the Comission's regulations; D. The issuance of this amendment will not be inimical to the comon defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Comission's regulations and all applicable requirements have been satisfied.

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2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-65 is hereby amended to read as follows:

(2) Technical Soecifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 158 , are hereby incorporated in the license.

The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of its issuance, to be implemented within 30 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION John F. St 1z, Director Project Directorate I-4 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: June 4, 1900 i

ATTACHMENT TO LICENSE AMENDMENT-NO. 158 FACILITY OPERATING LICENSE NO. DPR-65 DOCKET NO. 50-336 Replace the following pages of the Appendix A Technical-Specifications with the enclosed pages. The revised pages are identified b contain vertical lines.indicatin9 the areas of change. y amendment number and Remove Insert .;,

IX IX-XIV XIV 1-8 1-8 3/4 9-21 3/4 9-21 3/4 9-22 3/4.9-22 3/4 9-23 3/4 9-23 3/4 9-24 3/4 9-24 3/4 9-25 3/4 9-25 3/4 9-25a 3/4 9-26 3/4-S-26 3/4 9-26a B 3/4 9-3 8 3/4 9-3 B 3/4 9-4 B 3/4 9-4 5-5 S-5 5-Sa

g LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS _

SECTION EMI 3/4.9 REFUELING OPERATIONS 3/4.9.1 BORON CONCENTRATION ..................................... 3/4 9 1 3/4.9.2 INSTRUMENTATION ......................................... 3/4 9 2 3/4.9.3 DECAY TIME ......................t....................... 3/4 9 3 3/4.9.4 CONTAINMENT PENETRATIONS ................................ 3/4 9-4 3/4.9.5 C0mVNICATIONS .......................................... 3/4 94 3/4.9.6 CRANE OPERABILIIY - CONTAINMENT BUILDING ................ 3/4 9-6 3/4.9.7 CRANE TRAVEL - SPENT FUEL STORAGE POOL BUILDING.......... 3/4 9-7 3/4.9.8 SHUTDOWN COOLING AND COOLANT CIRCULATION ................ 3/4 9-8 3/4.9.9 CONTAINMENT _ RADIATION MONITORING ........................ 3/4 9 9 3/4.9.10 CONTAINMENT PURGE VALVE ISOLATION SYSTEM ................ 3/4 9-10 3/4.9.11 WATER LEVEL - REACTOR VESSEL ............................ 3/4 9-11 3/4.9.12 STORAGE POOL WATER LEVEL ................................ 3/4 9 12 3/4.9.13 STORAGE POOL RADIATION MONITORING ....................... 3/4 9 13 3/4.9.14 STORAGE POOL AREA VENTILATION SYSTEM - FUEL MOVEMENT .... 3/4 9 14 3/4.9.15 STORAGE POOL AREA VENTILATION SYSTEM - FUEL STORAGE ..... 3/4 9 16 3/4.9.16 SHIELDED CASK ........................................... 3/4 9 19 3/4.9.17 MOVEMENT OF FUEL IN SPENT FUEL POOL ..................... 3/4'9-21 3/4.9.18 SPENT FUEL POOL - REACTIVITY CONDITION .................. 3/4 9 22 3/4.9.19 SPENT FUEL POOL - STORAGE PATTERN ....................... 3/4 9-26 3/4.9.20 SPENT FUEL POOL - CONSOLIDATION ......................... -3/4 9 27 3f4.10 SPECIAL TEST EXCEPTIONS 3/4.10.1 SHUTDOWN MARGIN ........................................ 3/4 10-1 3/4.10.2 GROUP HEIGHT AND INSERTION. LIMITS ...................... 3/4 10-2 3/4.10.3 PRESSURE / TEMPERATURE LIMITATION - REACTOR CRITICALITY .. 3/4 10-3 MILLSTONE - UNIT 2 IX Amendment No. Q , JSA, Jppi ness JJ7, JU ,158

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SECTION E,Ag{

, 3/4.9.9 and 3/4.9.10 CONTAINMENT AND RADIATION MONITORING AND CONTAINMENT PURGE VALVE ISOLATION SYSTEM ................. B 3/4 9 2 3/4.9.11and3/4.9.12 WATER LEVEL - REACTOR VESSEL AND STORAGE POOL WATER LEVEL ................................. B 3/4 9 2 3/4.9.13 STORAGE POOL RADIATION MONITORING ................... B 3/4 9-3 3/4.9.14and3/4.9.15 STORAGE POOL AREA VENTILATION SYSTEM ... B 3/4 9-3 3/4.9.16 SHIELDED CASK ....................................... B 3/4 9-3 3/4.9.17 MOVEMENT OF FUEL IN SPENT FUEL POOL ................. B 3/4 9-3 3/4.9.18 SPENT FUEL POOL - REACTIVITY CONDITION .............. B 3/4_9-3 3/4.9.19 SPENT FUEL P001. - STORAGE PATTERN ................... B 3/4 9-4 3/4.9.20 SPENT FUEL POOL - CONSOLIDATION ..................... B 3/4 9 4 3/4.10 SPECIAL TEST EXCEPTIONS 3/4.10.1 SHUTDOWN MARGIN ..................................... B 3/4 10-1 i-3/4.10.2 GROUP HEIGHT AND INSERTION LIMITS ................... B 3/4 10-1 3/4.10.3 PRESSURE / TEMPERATURE LIMITATION REACTOR CRITICALITY ............................... B 3/4 10-1

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3/4.10.4 PHYSICS TESTS ....................................... B 3/4 10-1 3/4.10.5 CENTER CEA MISALIGNMENT ............................. B 3/4 10 1 3/4.11 RADIOACTIVE EFFLUENTS J/4.11.1 LIQUID EFFLUENTS .................................... B 3/4 11-1 3/4.11.2 GASEOUS EFFLUENTS ,.................................. B 3/4 11-2 3/4.11.3 TOTAL DOSE .......................................... B 3/4 11-4 I

MILLSTONE - UNIT 2 XIV Amendment No. JJ, JJf, JJJ, JJ7 0855 JJA158

DEFINITIONS ""

VENTING 1.35 VENTING is the controlled process of discharging air or gas from a confinement to maintain temperature, pressure, humidity, concentration or other operating condition, in such a manner that replacement air or gas is not provided or required during venting. Vent, used in system names, does not imply a VENTING process.

MEMBERfSi 0F THE PUBLIC 1.36 MEMBER (S) 0F THE PUBLIC shall include all persons who are not occupationally associated with the plant. This category does not include employees of the utility, its contractors or its vendors. Also excluded from this category are persons who enter the site to service equipment or to make deliveries. This category does include persons who use portions of the site for recreationti, occupational or other purposes not associated with the plant.

The term "REAL MEMBER OF THE PUBLIC" means an individual who is exposed to existing dose pathways at one particular location.

SITE BOUNDARY 1.37 The SITE BOUNDARY shs11 be that line beyond which the land is not owned, leased or otherwise controlled by the licensee.

UNRESTRICTED AREA 1.38 An UNRESTRICTED AREA shall be any area at or beyond the site boundary to which access is not controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials or any area within the site boundary used for residential quarters or industrial, commercial institutional and/or recreational purposes.

STORAGE PATTERN 1.39 The Region B and C spent fuel racks contain a cell blocking device in every 4th rack location for administrative control. This 4th location will be referred to as the blocked. location. A STORAGE PATTERN refers to a blocked location and all adjacent and diagonal cell locations surrounding the blocked location within the respective region.

L MILLSTONE - UNIT 2 1-8 Amendment No. Jpp, ;/7,158 caso

REFUELING OPERATIONS MOVEMENT OF FUEL IN SPENT FUEL POOL LIMITING CONDITION FOR OPERAT!ON 3,9,17 Prior to movement of a fuel assembly, or a consolidated fuel storage box, in the spent fuel pool, the boron concentration of the pool shall be maintained uniform and sufficient to maintain a boron concentration of greater than or equal to 800 ppa.

APPLICABILITY: Whenever a fuel assembly, or a consolidated fuel storage box, is moved in the spent fuel pool.

ACTION:

With the boron concentration less than 800 ppm, suspend the movement of all fuel in the spent fuel pool.

SURVEILLANCE REOUIREMENT 4.9.17 Verify that the boron concentration is greater than or ee"sl to 800 ppm within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to any movement of a fuel assembly, or t consolidated fuel storage box, in the spent fuel pool and every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> thereafter.

MILLSTONE - UNIT 2 3/4 9-21 Amendment No.- Jp), JJ7,158 eest

REFUELING OPERATIONS SPENT FUEL POOL--REACTIVITY CONDITION LIMITING CONDITION FOR OPERATION ,

3.9.18 The Reactivity Condition of the spent fuel pool shall be such that K,ff is less-than-or equal-to 0.95 at all times. l APPLICABILITY: Whenever fuel is in the spent fuel pool.

ACTION:

Borate until K,ff 1 95 is reached.

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SURVEILLANCE RE0VIREMENT 4.9.18.1 Ensure that all fuel assemblies to be placed-in Region C (as shown in Figure 3.9-2) of the spent fuel pool are within the enrichment and burn-up limits of Figure 3.9.1 by checking the assembly's design and burn up documen-tation.

4.9.18.2 - Ensure that the contents of each consolidated fuel storage box..to be placed in Region C (as shown in Figure 3.9-2) of the spent fuel pool are within the enrichment and burn-up limits of figure 3.9-3 by chec ting the design and burn up documentation for storage box contents.

4.9.18.3 Ensure that- all fuel assemblies to be placed in Region A-(as shown in Figure 3.9-2) of the spent fuel pool Are within the enrichment and burnup limits of Figure 3.9-4 by checking the assembly's design and burnup documentation.

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Mllt.5 TONE - UNIT 2 1/4 9-25a Amendment No. 158 l- eeat-

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REFUELING OPERATIONS

SPENT FUEL P0OL - STORAGE PATTERN ,

j LIMITING CONDITION FOR OPERATION 3.9.19.1' Each STORAGE PATTERN. of the Region C spent fuel pool racks shall-require either that:

1 .

(1) A cell blocking device is installed in those cell locations shown in Figure 3.9 2; or

! (2) If a cell blocking device has_ been removed. all cells of the STORAGE

PATTERN must- have consolidated fuel- in them,--including the - formerly
blocked location; or- '

1 l (3) Meet both (a) and (b):

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i (a) If a cell blocking ~ device has been removed. all cells of the l STORAGE PATTERN must have_ consolidated fuel in them except the -

o formerly blocked location.

I i (b) The formerly blocked location is vacant and a consolidated fuel

box or cell blocking device-- is imediately being placed into i the formerly blocked cell.

APPLICABILITY: Fuel in the Spent Fuel Pool

ACTION:T Take imediate action to comply with either 3.9.19.l(1)', (2) or (3). _

l SURVEILLANCE REQUIREMENTS 4.9.19.1 Verify that 3.9.19.1-is satisfied at_the:foll'ow'ing_ times.

i (1) Prior to removing a cell blocking device f- (2) Prior to removing a consolidated fuel storage box from its Region C storage location.

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i MILLSTONE - UNIT 2 3/4 9-26 Amendment No. JJ7, JJJ,158

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REFUELING OPERATIONS SPENT FUEL POOL - STORAGE PATJ1R!i e

LIMITING CONDITION FOR OPrRATION 3.9.19.2 Each STORAGE PATTERN of the Region B spent fuel pool racks shall require that

3 (1) A cell blocking device is installed in those cell locations shown in Figure 3.9-2; or (2) If a cell blocking device has been removed, all cells in - the STORAC: PATTERN must be vacant of stored fuel assemblies.

APPLICABILITY: Fuel in the spent fuel pool.

ACTION:

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Take immediate action to comply with either 3.9.19.2(1) or (2).

4 ggy11LLANCE RE0VIREMENTS-

! 4.9.19.2 Verify that 3.9.19.2 is satisfied prior to removing a cell blocking device.

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MILLSTONE - UNIT 2. 3/4 9-264 Amendment No. 158 0081

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! BASES 3/4.9.13 STORAGE POOL RADIATION MONITORING The OPERABILITY of - the storage pool radiation moritors ensures- that sufficient radiation , monitoring capability- is available to detect excessive radiation levels resulting - from 1)E the -inadvertent lowering. of the- storage- -

pool water -level or 2) the1 release --of - activity from an irradiated fuel i assembly, i 3/4.9.14 & 3/4.9.15 -STORAGE POOL AREA VENTILATION SYSTEM <

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, The limitations on the storage pool area ventilation-system ensures that-

l. all radioactive material released from an irradiated fuel assembly will- be i filtered through the HEPA filters and charcoal adsorber prior to discharge to the atmosphere. The OPERABILITY- of this system and -the resulting iodine-removal capacity are consistent with the assumptions of the_ accident. analyses, 3/4.9.16 SHIELDED CASK f

r The limitationsLof this apecification ensure-that in anievent'of a cask tilt accident 1) = the doses from ruptured fuel assemblies will be within the -

assumptions- of the safety analyses, 2). K,ff will-remain 1 95.

l 3/4.9 17 MOVEMENT OF FUEL'IN SPENT FUEL POOL The limitations of this' specification ensure that, in the event of'a fuel-l assembly or a consolidated fuel storage-box drop accident into a Region B or C j rack location completing a 4 out-of-4 fuel assembly geometry...K,ff will. remain

! 1 0.95.

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3/4.9.18 SPENT FUEL POOL - REACTIVITY CONDITION L

The limitations described byL Figures 3.9-1 and-- 3.9-3 ensure that the-reactivity of fuel-' assemblies and consolidated fuel storage- boxes, introduced into the Region-C spent fuel racks, are. conservatively within the assumptions-

- of the safety analysis.

The limitations described by Figure 3.9 4 ensure that- the reactivity of -

the fuel assemblies, introducted into the : Region: A spent: fuel racks are -

conservatively within the assumptions.of the-safety-analysis, i ..

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REFUELING OPERATIONS BASES 3/4.9.19 SPENT FUEL POOL - STORAGE PATTERN The limitations of this specification ensure that the reactivity l

conditions of the Region B and C storage racks and spent fuel- pool K,ff will ,

remain less than or equal to 0.95. l The Cell Blocking Devices in the 4th location of the Region C storage l racks are designed to prevent inadvertent placement and/or storage of fuel' essemblies in the blocked locations. The blocked location remains empty to provide the flux trap to maintain reactivity control for fuel assembly storage in any adjacent locations. Only loaded consolidated fuel storage boxes may be placed and/or stored in the 4th location, completing the STORAGE PATTERN,

.fter 311 adjacent, and diagonal, locations are occupied by loaded consolidated fuel storage boxes.

The Cell Blocking Devices is the 4th location of the Region B storage racks are designed to prevent inadvertent placement and/or storage _in the- blocked 1ccations. The blocked location remains empty to provide the flux trap to maintain reactivity control for fuel assembly storage in any adjacent locations. Region B is designed for the storage of new assemblies in the spent fuel pool, and for fuel assemblies which have not sustained sufficient burnup to be stored in Region A or Region C.

3/4.9.20 SPENT FUEL POOL - CONSOLIDATION The limitations of these specifications enP e that the decay heat rates and radioactive inventory of the . candidate fua! assemblies for consolidation are conservatively within the assumptions of the safety analysis.

MILLSTONE - UN!! 2 B 3/4 9-4 Amendment'No. JJ7, Jp ,158 0063

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d l DESIGN FEATURES 4

VOLUME i 5.4.2 The total water and steam volume of the reactor coolant system -is 10,060 + 700/-0 cubic feet.

- 5.5 EMERGENCY CORE COOLING SYSTEMS

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5.5.1 The emergency core cooling systems are designed and shall be maint'ained

. in accordance with the-original design provisions contained in Section 6.3 of-i the FSAR with allowance for nomal degradation- pursuant -_to 'the applicable Surveillance. Requirements.

- 5.6 FUEL STORAGE I L

! CRITICALITY 5.6.1 a) LThe new fuel (dry) storage -- racks are - designed and shall be-maintained with sufficient center to. center distance between assemblies to-1 95. The maximum nominal fuel enrichment. to be stored in ensure these racks a k'Id 4.50 weight percent of U-235.

i b) Region A of the spent- fuel storage pool 'is designed and _shall be l maintained with a_ nominal 9.8 inch center to center distance between storage

locations to ensure =a-K.,,1.85 vith the storage pool-- filled- with unborated water. Fuel assemblies m rd 1. als region must comply with Figure 3.9 4 to ensure thtt the design burnup nas been sustained.

c) Region B of the spent fuel storage pool is designed and shall be

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maintained with a nominal 9.8 inch centar-to-center distance between storage

, locations to . ensure - K f - 1.95 with _ a storage. pool - filled with unborated water. Fuel - assemblid fstored: in' this ' region may- have aJ maximum- nominal

enrichment of 4.5 weight percent U-235. Fuel- assemblies stored
in this region i are placed in a 3 out of 4 STORAGE PATTERN for reactivity control.=

i . d) Region C--of the- spent fuel? storage. pool: is' designed 'and shall be

. maintained with a 9.0 inch center to' center distance between-storage locations b-1 to ensure a K f 's- _.95 with- the storage pool- filled with - unborated water.

Fuel assemblief [tored in this- region must comply with- Fi ure 3.9-1 to ensure-that the design burn-up has been - sustained. Fuel assemb ies stored in this region are placed in a.3' out of'4 STORAGE PATTERN for reactivity control. ?The-contents of consolidated fuel storage boxes to be stored inithist region must comply with Figure 3.9-3.

E e) Region C of the ~ spent fuel storage pool- is designed _ to_~ permit storage of consolidated fuel in the 4th location of- the storage. rack and ensure a K 1 0.95. P1acement of consolidated fuel in- the.4th location- is 1 only.permiNd if all surrounding cells of the -STORAGE PATTERN are occupied by.

consolidated fuel.

MILLSTONE - UNIT 2 5-5 Amendment No. M, M. JA9, nu # 7, # 5158

- = . a .. a . ~.. - . - . . - . _ - . - . - - . -

DESIGN FEATURES DRAINAGE 5.6.2 The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 22'6".

CAPACITY 5.6.3 The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than 224. storage locations in Region A, 160 storage locations in Region B and 962 storage locations in Region C for a total of 1346 storage locations.*

  • This translates into 1237 storage locations to receive spent fuel and i 109 storage locations to remain blocked. I 1

1 i

i 1

MILLSTONE - UNIT 2 5-Sa Amendment No. 75, JS, JJJ, 4 4 cos: 777,ypg,158-1

pa my

% UNITED STATES E

I# .i NUCLEAR REGULATORY COMMISSION

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  • WASHINoTON, D.C. 20086 9

Q*.&A ..* 5 ,

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION j RELATED TO AMENDMENT NO. 158 TO FACILITY OPERATING LICENSE NO. OFR '

NORTHEAST NUCLEAR ENERGY COMPANY. ET AL.

MILLSTONE NUCLEAR p0WER STATI L UNIT NO. 2 DOCKET NO. 50-336

1.0 INTRODUCTION

By letter dated April 16, 1992, as supplemented by letter dated May 7,1992,-

Northeast Nuclear Energy Company (the licensee) proposed changes to the i

Millstone Unit 2 Technical Specifications (TS) which would modify the existing two-region spent fuel pool design to a three-region configuration. The May 7, 1992, letter provided information that did not change the initial proposed no significant hazards consideration determination.

These changes were proposed as a result of errors discovered in the spent fuel

, rack criticality analysis as reported to the NRC in Licensee Event Report 92-003-00, dated March 13, 1992. These calculational errors were due primarily to the incorrect treatment of thin, highly absorbing Boraflex panels and were

! discovered while performing criticality reanalyses associated with the

! Boraflex degradation. This prompted the issuance of NRC Information N'tice l 92-21 and its Supplement.

Presently, Region I of the Millstone Unit 2 spent fuel pool is designed-to store up to 384 fuel assemblies with an initial enrichment of up to 4.5 weight 4 percent (w/o) U-235. Region- I is comprised of five (5) rack modules and fuel assemblies can be stored in every location. The Region I. racks contain Boraflex and have a nominal center-to-center distance between storage.

locations-of 9.8 inches. Region II is designed to store up_to 728 fuel assemblies which have sustained a minimum required burnup as specified in TS Figure 3.9-3. Fuel assemblies are stored in a three-out-of-four array, with blocking devices installed' to prevent inadvertent placement of a fuel assembly in the fourth location. The Region II storage racks have a nominal center-to-center distance between storage locations of nine (9) inches and contain no Boraflex.

The proposed changes would result in a three-region configuration, described by alphabetic letters rather than-the previous numeric convention. Region A

-would utilize three of the existing Region I poison rack modules. Region A is designed to store up to 224 fuel assemblies, which will be qualified for storage by verification of adequate _ assembly average burnup versus fuel assembly initial enrichment. Fuel assemblies can be stored in every location

, in Region A. These racks would be used for immediate storage of fuel discharged from the reactor. Region B would utilize the remaining two existing Region I rack modules. Region B is designed to store up to 120 fresh U S l $ l 'f y _

(unirradiated) fuel assemblies with an initial enrichment of up to 4.5 w/o U-235 and other assemblies which do not satisfy the burnup versus initial enrichment requirements of either Region A or Region C. Fuel assemblies will be stored in a three-out-of-four array in Region B, with blocking devices installed to prevent inadvertent placement of a fuel assembly in the fourth location. Region C is the new designation for the existing Region 11 storage racks, de;igned for fuel assemblies which have sustained their design burnup.

Since this group of racks do not contain Boraflex, a reanalysis due to Boraflex degradation or due to previous calculational errors was not required.

2.0 EVALUATION On September 8, 1987, the NRC issued Information Notice No. 87-43 alerting all operating licensees that gaps had been found in the Boraflex panels of the spent fuel storage racks at Quad Cities Unit 1. In response to this, the licensee initiated blackness testing on the Boraflex panels in the Hillstone Unit 2 spent fuel storage racks. To date, approximately half of the poisoned rack cells in Region I have been tested. These measurements confirmed the presence of gaps in about If" of the irradiated panels with the largest observed gaps at a 2% shrinkage rate, resulting in a maximum gap size of approximately 2.825 inches. The licensee has, therefore, performed criticality analyses to demonstrate the safety of the storage racks accounting for gap formation.

The criticality analysis assumed 4% shrinkage resulting in 5.65-inch gaps at the observed test locations. The analysis also assumed a 4% gap formation with a random distribution in all of the other Boraflex panels. The staff considers these assumptions to be acceptable since the test data has only identified a maximum shrinkage of 2% and existing-industry-wide data supports a 4% maximum shrinkage rate. In addition, the random distribution of gap formation is also supported by the licensee's test data.

The NITAWL-KENO-5a computer code package was used in a three-dimensional mode with the 27-group SCALE neutron cross section set. This model has been benchmarked against experimental data and has been found to adequately reproduce the critical values. The original calculations for the Hillstone Unit 2 spent fuel pool used the 00T two-dimensional, discrete ordinates  !

transport code with cross sections generated by the CEPAK code, a synthecis of l FORM, THERMOS, and CINDER. As previously mentioned, the original calculations were found to be in error. The reactivity of the Region I spent fuel storage racks was underpredicted due to inaccuracies in predicting Boraflex absorption, thus resulting in a nonconservative analysis. A more recent analysis of the original Region I design using the NITAWL-KENO-Sa package resulted in a k-eff of 0.9812, assuming fully loaded racks of 4.5 w/o fuel and not accounting for Boraflex shrinkage. This does not meet the NRC 95/95 upper limit k-eff criterion of no greater than 0.95.

The licensee has, therefore, reanalyzed the Region I rack design with NITAWL-KENO-Sa assuming a three-out-of-four storage configuration (new Region B designation) with 4.5 w/o fresh fuel and 5.65-inch gaps at the locations observed in the Millstone 2 blackness tests and a random axial distribution of 5.65-inch gaps in all other Boraflex panels. The-resulting maximus k-eff, including all appropriate- biases and uncertainties, was 0.9179 for ANF fuel, 0.9252 for Westinghouse fuel, ad 0.9201 for CE fuel, all well within the 0.95 limiting criterion. The calculations also assumed a conservative shrinkage of 4% in width even though such shrinkage was not evident from visible inspections of Boraflex panels.

The o1J Region I rack design was also reanalyzed utilizing all of the cells in a four-out-of-four cell arrangement with credit for fuel burnup (new Region A designation). The same Boraflex gap distribution assumed in the Region B analysis was used. As seen from TS Figure 3.9-4, fuel with an initial enrichment of 4.5 w/o U-235 and minimum burnup of 8670 MWD /MTU is equivalent to unirradiated fuel enriched to 3.3 w/o U-235. The resulting maximum (95/95) k-eff was 0.9317 fo* ANF fuel, 0.9381 for Westinghouse fuel, and 0.9335 for CE fuel, all within tL 0.95 limiting criterion, it is possible to postulate events, such as the inadvertent misloading of an assembly with a burnup and enrichment combination outside of the accestable area or the placement of a fresh assembly in the fourth cell of the t1ree-out-of-four configuration, which could lead-to an increase in reactivity.

However, for such events, the Double Contingency Principle allows credit for the presence of approximately 800 ppm of boron in the pool water required by TS whenever a fuel assembly is being moved _in the spent-fuel pool. The reduction in k-eff caused by the boron more than offsets the reactivity addition caused by credible accidents.

The following TS changes have been proposed as a result of the reanalysis of the Millstone Unit 2 spent fuel pool. The staff finds these changes acceptable as well as the associated Bases changes.

(1) Definition 1.39, STORAGE PATTERN is currently defined for Region 11.

This is being changed to define the three-out-of-four array to-be used in Regions B and C.

(2) TS 3.9.17 is currently concerned with_ fuel _ movement over Region II racks (due to the dropped assembly accident and misplaced fuel assembly

[ event). This is being changed from any fuel movement over the Region 11 racks to any fuel movement in the spent fuel pool.

(3) TS 3.9.18 is being modified to change the wording in the surveillance requirements from Region II to Region C, and adds a surveillance requirement to ensure that fuel assemblies to be placed in Region A are within the enrichment and burnup limits of a new Figure 3.9-4.

(4) Figure 3.9-1 is being modified to change the references from Region 11 to Region C.

l 4

(5) Figure 3.9-2 is being modified to delete the references from Regions I and 11 and add Regions A, B, and C.

(6) Figure 3.9-3 is being modified to change the references from Region !!

to Region C.

(7) A new Figure 3.9-4 is being added to specify the allowablo enrichment and burnup limits for fuel assemblies to be stored in Regien A.

(8) TS 3.9.19 is being split into two parts:

(a) TS 3.9.19.1 is the old TS 3.9.19, changing the references from Region 11 to Region C.

(b) TS 3.9.19.2 is a new r6quirement fo? the STORAGE PATTERN requirements of Region B.

(9) The Design Features section for Fuel Storage Criticality and Capacity

) are being changed to describe the design features for the newly defined regions (A, B, and C), as well as to change the storage capacity numbers to reflect the blocked locations in Regions B and C.

(10) The Bases sections for TS 3.9.17, 3.9.18, and 3.9.19 are keing changed to reflect the changes introduced by the new spent fuel storage rack criticality design basis.

Based on the review described above, the staff finds tb criticality aspects of the proposed Millstone Unit 2 spent fuel stcrage pool changes acceptable.

Specifically, with the conservatively postulated maximum 5.65-inch gaps in all Boraflex panels, the spent fuel storage racks can safely accomodate spent fuel from Millstone Unit 2 of the burnup-er,richment combinations indicated in TS Figure 3.9-4 (Region A) or Figure 3.9-1 (Region C) using all cells in a fou -out-of-frur arrangement. In addition, Region B can safely accomodate froh 4.5 w/e U-235 Millstone Unit ? fuel in a three-out-of-four loading pattern with the fourth cell empty.

3.0 STATE CONSULTATION

In accordance with the Comission's regulations, the Connecticut State official was notified of the proposed issuance of the amendment. The State official had no comments.

4.0 PUBLIC COMMENTS Hs Patricia R. Nowicki, representing Earthvision Inc., by letter dated H;y 27, 1992, requested a public hearing on this matter citing that "...it would be in the best interest of both Northeast Utilities as well the welfare of the citizens of this area that the licensee proude background information to the public as tS the need for and the safety of said amendment." The staff has considered Ms. Nowicki's comments and has concluded that there is nothing in

them that would cause the staff to change the proposed no significant hazards consideration determination.

Ms. Mary Elle, Herecci of New Haven, Connecticut, by letter postaarked May 28, 1992, requested a hearing and a wish to intervene and an implied request for a 10 day delay in the issuance of the amendment citing a concern that "...there is significant unacceptable hazards risk if the spant fuel pool were to be utiliTod under planned conditions to occur on June 14, 1992, and that the design question of criticality calculations in that pool may not have been re r olvec' . Also the ramoval of criticality monitors as allowed by the NRC in an experimental fuel consolidation program that is on-going may not have been prudent." The NRC staff has considered Ms. Marucci's comments and has concluded that there is nothing in them that would cause the staff to change the proposed no significant hazards consideration determination.

In a telephone conver:ation Mr. Michael Pray of New London, Connecticut, on May 28, 1992, indicated that he would file a request for a hearing. That request has not yet been received nor have Mr. Pray's comments.

5.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION

DETERMINATI03 The Commission's regulations in 10 CFR 50.92 state that the Comniission may make a final determination that the license amendment involves no significant hazards consideration if operation of the facility, in accordance with the amendment, would not:

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

. Radiological consequences of the fuel handling accident are not impacted by the formation of Regivns A and B because the fuel assembly design is unchanged. However, the probability of occurrence of a fuel misplacement error has increased slightly. The increase is not significant because the types of controls being put into place in Regiont A and B are of the same type as already in place in Region C. Furthenrore, a fuel assembly misplacement error is not considered an accident, as defined in the Final Safety Analysis Report.

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

No changes are being made to the fuel assemblies or the storage racks, and controls used in the fuel pool will be of the same type as are now in place. As such, there is no possibility of a new or offferent kind of accident being created. The existing design basis covers all possible accident scenarios in the spent fuel pool.

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3. Involve a significant reduction in a margin of safety.

There is no reduction in the margin of safety since K 50.95 is met under all analyzed conditions using conservative assumptions which do not credit the soluble boron in the spent fuel pool except under some accident conditions, as allowed by NRC guidelines. Tne original mechanical analyses are unchanged for thermal Snd seismic / structural considerations.

Accordingly, the NRC staff concludes that the proposed amendment involves no significant hazards considerations.

6.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined ir 10 CFR Part 20. The NRC staff has determined that the amendment involvt. e significant increase in the amounts, and no significant change in :st type;,

of any effluents that may be released offsite, and that there is . ;

significant increase in individual or cumulative occupational rr;iktion exposure. The Comission has made a final no significant hazards consideration determination with respect to this amendment. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 u k Sl.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

7.0 (QNCLUSION The Comission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safet public will not be endangered by operation in the proposed manner,y of the activities will be conducted in compliance with the Comission's regul(2) such t.tions, and (3) the issuance of the amendment will not be inimical to the comon defense and security or to tre health and safety of the public.

Principal Contributor: L. Kopp Date: June 4, 1992 t

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