ML20199J659

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Application for Amends to Licenses NPF-68 & NPF-81,revising TS to Change Capacity of Unit 1 Spent Fuel Storage Pool from 288 to 1476 Assemblies & Design Features Description to Reflect Criticality Analyses & Storage Cell Spacing
ML20199J659
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 11/20/1997
From: Mccoy C
SOUTHERN NUCLEAR OPERATING CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20199J664 List:
References
LCV-0828-B, LCV-828-B, NUDOCS 9711280193
Download: ML20199J659 (12)


Text

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k C. K. McCoy Southern Nuclear thce President Operating Company. inc.

Vogtle Project. _40 inverness Center Padway PO Box 1295 Bemirgham. Alabama 35201 Tel2059923122 fax 2059920403 Docket Nos. 50-424 and 50-425 November 20, 1997 SOUTHERN U. S. Nuclear Regulatory Commission COMPANY ATTN: Document Control Desk meg te stru reurruru-Washington, D. C. ' 20555 LCV-0828-B Gentlemen:

VOGTLE ELECTRIC GENERATING PLANT '

REQUEST TO REVISE TECHNICAL SPECIFICATIONS ADDITIONAL FUEL STORAGE RACKS FOR UNIT 1 FUEL STORAGE POOL in accordance with the provisions of 10 CFR 50.90 and 10 CFR 50.59, Southern Nuclear Operating Company (SNC) hereby requests an amendment to the Vogtle Electric Generating Plant (VEGP) Unit I and Unit 2 Technical Specifications, Appendix A to Operating Licenses NPF-68 and NPF-81. The revision to the Technical Specitications will change the capacity of the Unit I spent fuel storage pool from 288 to 1476 assemblies, and revise the design features description to reflect the criticality analyses and storage cell spacing.

The spent fuel storage pool for VEGP Unit 2 contains storage racks with a sto: age capacity for 2098 fuel assemblics. The Unit i fuel storage pool was designed and constmeted to be the same as the Unit 2 fuel storage pool except that only two racks with a capacity of 288 storage locations were installed in the Unit I pool. Southern Nuclear proposes to replace the two racks in the Unit 1 pool with 26 racks with a capacity for storage of 1476 assemblies. These racks were previously licensed by the NRC and used at the Maine Yankee Nuclear Plant.

A report entitled " Modification Report for Spent Fuel Pool Increased Storage Capacity,"

prepared by SNC with assistance from its contractor, Holtec International, was previously transmitted to the NRC with letter LCV-828-A. The report demonstrated that installation and use of these racks, in the VEGP Unit I fuel storage pool. can be achieved with respect i j

f to thennal-hydraulic considerations, seismic and structural adequacy, radiological //

I compliance, and mechanicalintegrity. The report did not include the results of the criticality analyses.

This letter requests the Technical Specifications changes required for use of the additional spent fuel storage capacity. It includes the results of criticality analyses performed using , j the recently approved methodology described in Westinghouse WCAP-14416-NP-A Rev. 2l f 1, " Westinghouse Spent Fuel Rack Criticality Analysis Methodology," November,1996.

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LCV-0828-B Page 3-By letter LCV-0849-E, SNC requested revisions to the Technical Specifications for the storage of spent fuel that would allow credit for soluble boron, burnup, and storage ,

configurations for storage of fuel with initial enrichments up to 5.0 weight percent U-235.

That change to the Technical Specifications is currently being reviewed by the NRC staff ,

and is expected to be approved by about January 31,1998. It is the intention of SNC to replace the two spent fuel racks currently in the Unit I spent fuel pool with 26 racks '

containing' 1476 storage locations. Therefore, the Technical Specif. cations proposed by this letter are presented as a marked up version of the technical specifications as submitted to the NRC by LCV-0849-E. The criticality analyses described in this letter were

- performed in accordance with the same methodology described in LCV-0849-E.

In a meeting on January 16,1997, SNC informed the NRC of the intent to install replacement fuel storage racks on a schedule consistent with the receipt and str":de of new fuel in the fall of 1998, for the spring 1999 refueling outage of VEGP Unit 1. To -

meet this schedule, work must start shortly afler the Unit 2 refueling outage which begins in March of 1998. Therefore, SNC requests that this change to the Technical Specifications be re"iewed by April 15,1998. This schedule is consistent with an installation schedule that allows the replacement to be conducted when there are no fuel assemblies in the Unit I pool,'and during a time when there are no other concurrent refueling or fuel receipt activities in the fuel storabe building.

Enclosure I contains a description of the change, enclosure 2 contains an evaluation in accordance with 10 CFR 50.92 which concludes that there are no significant hazards considerations, enclosure 3 includes the revised Technical Specification pages, enclosure 4 L provides an environmental assessment and enclosure 5 includes the results of the criticality analyses.

Mr. C. K. McCoy states that he is a Vice President of Southern Nuclear and is authorized to execute this oath on behalf of Southern Nuclear and that, to the best of his knowledge -

and bel:ef, the facts set forth in this letter and enclosures are true.

SOUTHERN NUCLEAR OPERATING COMPANY By: _ -

C.K.Mc y Sworn to and subscribed before me thisM ay of d ,1997. ,

I-St@ .

'4 Not'ary Pdblic -

LCV-0828 Il Page 3 CKM/llWM/gmb Encbsures:

1, liases for Proposed Change 2.10 CFR 50.92 Evaluation

3. Instructions for incorporation and revised pages
4. IInvironmental Assessment
5. Criticality Analyses c(w): SDulltem&dcat Mr. J.11. Ileasley, Jr.

Mr. M. Sheibaal ,

NORMS U. S NudcatBegulatory Cornminion Mr. L A. Reyes, Regional Administrator Mr. L 1. Wheeler, Senior Project Manager, NRR Resident inspector, Vogtle Slalc_010colgiJi Mr. L C. Ilarrett, Commissioner, Department of Natural Resources

ENCLOSURE 1 VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECilNICAL SPECIFICATIONS ADJ21110NAl FUEL STOIMQl1JMCKS10R UNIT I FUEL STORAGE POOL 11 ASIS FOR PROPOSED CilANGE Proposed Changes:

The Vogtle Electric Generating Plant Unit I and Unit 2 s, ent fuel pools are the same size and design, each with itu own independent and redundant cooling systems. The Unit 2 pool has been hiled with fuel storage racks with 2098 fuel storage locations. The Urit 1 pool currently contains only two racks containing the neutron absorbing material, boraflex, with a capacity for storage of 238 fuel assemblies. The two racks in the Unit 1 pool are being replaced with 26 rachs utilizing the neutron absorbing material, boral, with a storage capacity of 1476 fuel assemblies The proposed changes to the Technical Specifications indicate the revised storage capacity, and the parameters associated with the criticality analyses for these racks. The criticality analyses were performed using the NRC approved methodology described in WCAP-14416 NP A Rev.1, November,1996.

Revisions to the Technical Specifications Replace figure 3.7.181 with a revised figure based on the criticality analyses for the Unit I racks containing boral.

The criticality information for Unit 2 is being placed unchanged into section 4.3.1.2 and 4.3.1.1. is being revised to address Unit 1 Revise Design Features section 4 3.1.1.c to indicate 600 ppm as the required amount of soluble born to maintain K n 5 0.95.

Revise Design Features section 4.3.1.1.d to include the reference K. that is equivalent to the combination of burnup and initial enrichment defined by figure 3.7.18 1.

Revise Design Features section 4.3.1.1.c to indicate that fuel assemtlies with up to 5 weight percent U-235 may be stored in 3-out of-4 checkerboard storage configurations, delete figure 4.3.1-1, eliminate the reference to 2-out-of.4 storage for the Unit 1 pool and include the reference K. acceptable for all cell storage in the Unit I fuel storage racks.

Revise Design Featuns section 4.3.1.1.f 3 include the pitch of the Unit I fuel storage racks.

Revise Design Features section 4.3.3 to indicate 'he Unit 1 fuel storage pool capacity of 1476 fuel assemblies.

Revise titles on figures 4.3.1-4,4.3.16 and 4.3.1-7 to reflect the elimination of 2-out-of-4 storage configuration requirements for the Unit I fuel storage pool El.1

ENCLOSURE 1 VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECllNICAL SPECIFICATIONS ADDillONAL FUEL SIDMGil. RACKS FOR UNIT 1 FUEL STORAGE POOL IIASIS FOR PROPOSED CilANGE (Continued)

Revise bases section 113.7.17 to indicate that 600 ppm of soluble boron is required for maintaining Kar of the Unit I poolless than or equal to 0.95, to indicate that the misplacement of a fuel assembly between the rack and the pool wall was also evaluated, arid to indicate a reduction in the required boron cencentration to offset an accidenti n the Unit 1 fuel storage pool.

Revise bases section 113.7.18 to include the results of the Unit 1 fuel storage criticality analyses.

linis:

lly letter LCV-0849 E Southern Nuclear Operating Company (SNC) proposed changes to the Unit I and Unit 2 technical specifications that based the criticality analyses on the recently NRC approved methodology described in WCAP 14416 NP-A Rev.1, November 1996. Those changes to the technical specifications are expected to be approved by the NRC about January 31.1998. The technical specification changes now being proposed are in addition to those contained in LCV-0849 E. They have the tame analytical methodology and bases. The number of fuel storage locations is increased in the Unit i fuel storage pool and the criticality analyses have been reperformed for the boral racks.

Ilecause these racks have boral as a neutron absorber, they are capable of storing fuel with up to 5.0 weight percent in a 3-out of-4 checkerboard configuration without credit for burnup or IFil A; thus, there is no need for defining 2-out-of-4 checkerboard restrictions for the Unit I fuel storage racks Typically, fuel with enrichments approaching 5.0 weight percent has suflicient burnable absorber to give it a reactivity equivalent to an enrichment ofless than or equal 3.5 weight percent. That equivalent reactivity is being added to the Design Features acetion. These racks and the associated technical specifications will allow any fuel that is anticipated to be used at VEGP to meet the all cell storage requirements.

Therefore, once approved and installed, these racks will simplify the practical fuel storage requirements, and greatly reduce the possibility of a misplacement of a fuel assembly in the fuel storage pool llecause the Unit I and Unit 2 pools are connected, the additional flexibility created by the addition of the fuel storage racks with boral neutron absorber in the Unit I fuel storage pool will also benefit the Unit 2 fuel storage pool.

The proposed changes to the technical specifications are in enclosure 3. Enclosure 3 includes a marked up versica of the technical specifications as submitted to the NRC by LCV-0849-E. Installation of the boral racks will begin shortly after the Unit 2 refueling outage, in the Epring of 1998. The installation schedule is designed to allow the racks to El 2

ENCLOSURE 1 VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECilNICAL SPECIFICA1'ONS ADD 1ILONAL FUEL STDMGE RACKS FOR UNIT 1 FUEL STOMOE POOL llASIS FOR PROPOSED Cl{ANGE (Continued) be installed while there is no fuel in the Unit 1 pool. The analytical bases for the limits l proposed for the technical specifications were calculated using NRC approved methods l and are consistent $vith the information and analyses presented in LCV-0849 E. The  ;

physical design of the boral racks and the evaluation of: heir installation were sent to the l NRC by letter LCV-0828 A dated September 4,1997. The capacity of the Unit I fuel storage pool remains well within the capacity which has already been reviewed and accepted by the NRC for the Unit 2 pool. Therefore, SNC has requested that this revision be reviewed by April 15,1998.

El 3

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ENCLOSURE 3 VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECilNICAL SPECIFICATIONS AlWIDONAL FUEL STORAGE RACKS FOR UNIT I FUEL STORAGE POOL 10 CFR 50.92 EVALUATION 83ackground Each of the Vogtle Electric Generating Plant (VEGP) Units has an independent fuel storage pool Each pool has it own independent, redundant cooling system. The two pools are connected to a shared spent fuel cask loading pit. This allows fuel to be moved between the two fuel storage pools. The Unit 2 poolis completely filled with fuel storage racks and has 2098 storage locations. The Unit 1 pool, even though designed and built the same as the Unit 2 pool, only has two racks with 288 storage locations.

The racks in each pool contain the neutron absorbing material boraflex. Horaflex is being eliminated from the licensing basis of the fuel storage racks. By letter LCV-0849 E, SNC proposed changes that eliminate credit for the borauex, from the bases for meeting NRC requirements for mair,taining the fuel storage poolin a suberitical condition. That requen was based on revised analyses performed in accordance with the recently NRC approved rnethodology contained in WCAP-14416 NP A, Rev.1 " Westinghouse Spent Fuel Rack Criticality Analysis Methodology," November,1996. The analyses dermed combinations of burnup and initial enrichments that can be stored in the fuel storage racks, without credit for boraflex. It also dermed acceptable checkerboard loading phaerns, interface requirements or equivalent K. for storage of fuel that does not meet the combination of initial burnup and enrichment. Those changes, which are currently being reviewed by the NRC, will allow complete utilization of the storage capacity of both pools without reliance on credit for boraflex as a neutron absorbing material.

The proposed addition of the storage racks containing boral as a neutron absorbing material, not only increases the fuel corage capacity but also climinates a source of silica contamination in the fuel storage pool coolant The analyses demonstrate that the fuel storage racks containing boral meet the suberiticality requirements with fuel up to the maximum allowable enrichment with a minimum of burnup. The anrJyses show that the K. requirements are met for unburned fuel containing integral fuel burnable absorbers (IFB A) within the range of that which is normally included in higher enriched fuel. Fuel enrichraent and IFDA combinations that are currently expected to be used in the future, would probably not acquire checkerboard storage. Therefore, in addition to providing more storage capacity, the proposed changes will allow simplified administrative controls for assuring that the storege is in accordance with the regulatory and design bases.

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ENCLOSURE 2 VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECIINICAL SPECIFICATIONS AR21TIONAL FUEL STORAGE RACKS FOR UNIT I FUEL STORAGE POOL 10 CFR $0.92 EVALUATION (Continued)

Proposed Changes The proposed changes are described in enclosure 1. The marked up technical

! specifications are includei in enclosure 3. The changes incorporate the increased number of fuel storage locations in the Unit 1 pool Changes to the design features section are necessary to be consistent with the criticality analyses, and the inclusion of the reference K. for all cell storage in the Unit I fuel storage racks. The marked up pages are revisions to the specifications that were proposed by letter LCV-080-E.

Safety Evaluation i The potential safety consequences for this change are those associated with the physical rack change and the increased number of fuel assemblies, and those associated with the requirements to maintain the poolin a suberitical condition. These are addressed below. 1 H @ Installation

! <e Vcval of the existing racks and the installation of the new racks has been described bJ Jyf& ation Report for increased Spent Fuel Pool Storage Capacity" which was transmincJ to the NRC with letter LCV-0828 A on September 4,1997. The installation

(. of the racks will be accomplished while there are no fuel assemblies in the Unit I fuel storage pool. This greatly reduces the risks associated with the movement of heavy loads associated with installation. Because the racks were previously installed and used for fuel storage at another plant, and because fuel has been previously stored in the Unit 1 fuel storage pool, precautions will be taken to minimize radiological exposure to personnel during installation.

llent Loads

'l he additional storage capacity of the Unit i pool wdl icsult in actual peak heat loads less than those resulting from the currently licensed configurations. The current fuel storage arrangement for the two units requires that fuel from Unit 1 be stored in the Unit 2 pool because it contains a larger number of storage locations. The discharged fuel from Unit 1 is transferred to the Unit 2 pool prior to the next Unit I refueling outage. The Unit 2 pool was analyzed to demonstrate that it is capable of removing the increased decay heat due to the storage of fuel assemblics from both units. This analysis is described in FSAR section 9.1.3. The analysis was reviewed by the NRC and the conclusions documented in Safety Evaluation Report (SER) NUREG 1137, supplement 8. The SER acknowledged that the analyzed heat loads were increased to account for storage of discharged fuel from two units and that the analyses were also applicable to the Unit I fuel pool cooling system.

The increased storage capacity of the Unit I pool reduces the requirements for movement of fuel between the two pools. This will result in peak heat loads that are lower than those that are currently projected for the arrangement of 2098 storage locations in one pool and 288 in the other pool. Therefore, the increased storage capacity of the Unit I pool will j E2 2

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ENCLOSURE 2 VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECilNICAL SPECIFICATIONS ADDITIONAL FUEL STQRAGE RACKS FOR UNIT 1 FUEL STORAGE POOL 10 CFR 50.92 EVALUATION (Continued) not result in heat loads that are in excess of those previously reviewed and accepted by the NRC. The analyses which are described in the FSAR included assumptions about fuel cycles and fuel discharge schemes that were chosen to assure that full uti!Mation of the pool would be achieved while remaining within the analyzed heat loads. The actual number and power history of fuel assemblies remaining in the pool following a refueling outage depends on the fuel cycle design for :ach operating cycle.

It is the practice at VEGP, to verify that the pool heat loads, resulting from each significant fuel transfer either from the reactor or between the pools, will remain within the heat loads used in the analyses. The report transmitted to the NRC with LCV-0828-A, included an analysis of fuel pooi temperature demonstrating that the previously licensed pool temperature limit for only one train of fuel pool cooling is met with a steady state heat load of about 5187x10'lltu/hr. The steady state heat load assumption is very conservative because a typical full core has a decay heat load of about 40x10' Iltu/hr at 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> after shutdown, it has decayed to about 32x10' Dtu/hr afler r.n additional 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br />, and continues to decay rapidly.

Structural Analysis The racks and their interface with the Unit I fuel storage building have been extensively evaluated, including a complete seismic evaluation. The total mass of racks and fuel assemblies is less than that which was already analyzed, reviewed and accepted for the Unit 2 pool. Because these racks were previously licensed for use at another plant with a difTerent seismic design requirement, the racks have been reanalyzed for the appropriate VEGP seismic criteria. The results of the seismic analyses are included in the report submitted with LCV-0825 A. That report describes analyses demonstrating that the stmetural integrity of the fuel, fuel cells, rack modules, fuel storage pool walls and floor will be maintained during postulated seismic and accident conditions.

Criticality Topical report WCAP 14416-P A describes a methodology for analyses of fuel storage rack criticality. This methodology has been reviewed by the NRC and determined to be acceptable for fuel storage rack criticality analyses. Analyses using this methodology have been performed and revisions to the technical specifications have been proposed for the storage of fuelin both the Unit I and Unit 2 fuel storage pools. Those analyses were submitted to the NRC by letter LCV-0849-E, dated August 8,1997. Approval of those changes is expected about January 31,1998. The criticality analyses, and proposed technical specifications changes being proposed for the racks to be placed in the Unit 1 pool, were performed using the same methodology. Therefore, the changes are described in terms of revisions to the Technical Specifications as they will be following approval of the request made by LCV-0849 E.

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ENCLOSURE 2 VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECliNICAL SPECIFICATIONS ADDITIONAL FUEL STORAGilMCKS FOR UNIT 1 FUElJiTORAGE POOL 10 CFR 50.92 EVALUATION (Continued)

The criticality methodology requires a calculat%n demonstrating that K,a remains below I.0 (suberitical) with no credit for soluble boron. The amount of boron required to assure that the K,n remains 5 0.95 is then determined in accordance with the methodology described in the topical report For higher enrichments (up to 5.0 weight percent U 235),

reactivity equivalencing methodologies in accordance with the topical report are used to determine burnup or IFilA credit.

The details of these analyses and the re.;ults are describe in the criticality analysis summary report in enclosure 5. .

The results demonstrate that fuel assemblics with enrichments up to 3.5 weight percent U-235 may be stored in all cell locations and fuel assemblies with higher enrienments may be stored in all cells provided thy meet burnup or IFilA content requirements. Fuel assemblies with initial enrichments up to 5.0 weight percent U 235 may be stored in 3 out-of 4 checkerboard patterns without credit for burnup. Fuel assemblies with initial enrichments of 5.0 weight percent U-235 and a burnup of 9786 MWD /MTU may be stored in all cells of the Unit 1 fuel storage racks. Fuel with initial enrichments of up to 5.0 weight percent U-235 ar.d having sufficient IFIlA to result in a K., s 1.431 in cold reactor conditions may be stored in all storage cells. The required number of 1.5 X IFilA to meet this condition is 48. Ilased on these results, it is expected that the types of fuel currently planned for use at VEGP will meet the all cell storage requirements for the new Unit I storage racks.

The fuel pool boron concentrations pieviously proposed in LCV-0849 E included an allowance to assure that K,n remains less than or equal to 0.95 under accident conditions.

The new Unit I racks utilize a flux trap design taking credit for boral as a neutron absorbing material. Therefore, an additional evaluation of an accidental placement of a fuel assembly outside the racks was considered. The results of the criticality analyses indicated that the required baron concentration to maintain K,n s 0.95 is 600 ppm. The amount of boron required to ofTset the effects of accidents was determined to be 800 ppm.

Enclosure 6 to LCV-0849 E provided an evaluation to demonstrate that very large amounts of water would be required to accidentally dilute the fuel storage pool to the boron concentration where K,n could exceed the 0.95 limit. The increase in the boron concentration required to offset the unplanned dilution by maintaining K,n s 0.95 is small relative to the specified limit of 2000 ppm and the typical value of 2400 ppm. The utilization of the new racks for the Unit 1 pool will not significantly affect the ability to detect and terminate an inadvertent boron dilution event. Therefore, the proposed change does not alter the conclusions concerning the potential for an inadvertent dilution of the fuel storage pool.

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ENCLOSURE 2 i VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECilNICAL SPECIFICATIONS ADDITIQNAL FUEL STORAGE RACKS _):OR UNIT 1 FUEL STORAGE POOL ,

1 1

10 CFR 50.92 EVALUATION (Continued)

Determination of No Significant llazards: i The proposed changes to the Operating License have been evaluated to determine whether they constitute a significant hazards consideration as required by 10 CFR 50, Section 50.91 using the standards provided in Section 50.92. The results are provided below:

1. The analyses methodologies are the same as previously approved for use by the NRC.

The results of the analyses resulted in fuel pool boron concentrations, and fuel assembly storage limitations that are similar to those already submitted to the NRC.

The increased number of fuel assemblics will remain less than the number previously accepted by the NRC for storage in VEGP Unit 2, which has a similarly designed and constructed facility, with the exception of the number of fuel storage locations.  ;

Therefore, based on the conclusions of the above analysis, the proposed changes will not involve a rignificant increase in the probability or consequences of an accident previously evaluated.

2. The effects of accidents that could affect the fuel were analyzed for the fuel storage racks, however the types of accidents have not changed. The fuel to be stored in the Unit I poolis expected to meet the all cell storage requirements. The racks wil' be placed in the Unit I pool without lifling any loads over spent fuel. After installation of the new racks, the Unit 1 pool will have 1476 storage locations which is well within the 2098 locations that the pool and stmeture is capable of storing, based on its similarity to the Unit 2 pool.

Therefore, the proposed changes will not create the possibility of a new or ditTerent kind of sceident.

3. The changes to the technical specifications are necessary to incorporate the parameters resulting from the criticality analyses, The criticality analyses were performed using methods and criteria previously accepted by the NRC. The requirements are similar to the previously submitted requirements. The margins of safety provided by the previous technical specifications are not significantly affected because the new racks are based on the same acceptance values. The larger number of fuel assemblies to be stored in the Unit 1 pool remains well within the capability of the pool.

Therefore, the proposed changes in this license amendment will not result in a significant reduction in the plant's maigin of safety.

E2 5

ENCLOSURE 2 f.'

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECIINICAL SPECIFICATIONS ADDITIONAL FUEL STORAGE RACKS FOR UNIT 1 FUEL STORAGE POOL 10 CFR 50.92 EVALUATION (Continued)

Conclusion:

Based on the evaluation above, and parsuant to 10 CFR 50, Section 50.91, Southern Nuclear has determined that operation of the Vogtle Electric Generating Plant in accordance with the proposed license amendment request does not involve any significant hazards considerations as defined by NRC regulations in 10 CFR 50, Section 50.92.

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