ML20132C433
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I WASHINGTON, D. C. 20555 DCT 161984 MEMORANDUM FOR: Thomas M. Novak, Assistant Director for Licensing, Division of Licensing FROM:
L. S. Rubenstein, Assistant Director for Core and Plant Systems, Division of Systems Integration
SUBJECT:
BEAVER VALLEY UNIT 2 APPEAL ISSUES - SPENT FUEL POOL HEAT LOAD, AUXILIARY SYSTEMS BRANCH In response to your memorandum dated October 11, 1984, the Auxiliary Systems Branch is providing the following discussion concerning the spent fuel pool cooling system and fuel pool heat load issue (0 pen Item #134) identified for appeal by the Beaver Valley Unit 2 applicant. As discussed previously with G. Knighton, DL and indicated in my note to you of August 1,1984, we continue to believe that this issue does not warrant an appeal.
The spent fuel pool cooling system must satisfy the requirements of General Design Criterion 44 which states in part "The system safety function shall be to transfer the combined heat load of these structures, systems, and components t
(i.e., those important to safety) under normal operating and accident condi-tions." We therefore believe it is not only logical to assume a full spent fuel pool when calculating heat removal capability but that this is the assump-
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i tion intended in order to demonstrate compliance with GDC 44. We understand the applicant's position to be that they have analyzed the spent fuel pool cooling system design capability for normal conditions based on the heat generated from 1-1/3 cores of successive refueling discharges as prescribed I
in the criteria of SRP Section 9.1.3 and on that basis comply with applicable I
regulations. As we indicated previously in the August 1, 1984 note, the SRP criteria is not correctly worded and will be revised in the future.
- However, it should be noted that SRP Section 9.1.3 also states that the spent fuel pool cooling system shall be capable of heat removal from a fully loaded pool which for Beaver Valley Unit 2 is 1088 fuel assemblies, considerably more than 1-1/3 Cores.
1 As we indicated in the August 1, 1984 note, it is our opinion that no safety significant issue exists in regard to this open item. We believe that the spent fuel pool cooling system will be found acceptable assuming a heat load based on a full storage pool. However, since the applicant has yet to demon-strate this, we offer the applicant two alternatives as follows:
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Revise the FSAR to incorporate a spent fuel pool cooling system normal heat removal analysis assuming the pool is full of successive refueling dischar9es in order to assure compliance with GDC 44 for the present design, or i
Contact:
J. Wermiel X29462
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OCT 10 ss4 2.
Since the current FSAR heat load analysis is for no more than 1-1/3 cores, propose a technical specification r accept a license condition for storage of no more than this amount o fuel as no analysis for safe storage of greater than this amount has een 9 resented. When the appli-j cant chooses to store greater than_1-1/ -cores, an appropriate license amendment would be required along with the required supporting analysis.
As previously stated, we believe an appeals meeting on this issue is unnecessary. We are available to discuss this further.
L. S. Rubenstein, Assistant Director for Core and Plant Systems Division of Systems Integration cc:
R. Bernero D. Eisenhut
- 0. Parr G. Knighton J. Wermiel B. K. Singh R. Anand M. Ley I
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