ML20204H978

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Proposed Tech Specs,Revising Sections 3.7.15,3.7.16,4.3.1 & 4.3.3 to Support Installation of New Boral high-density SFP Storage Racks at Byron & Braidwood Stations
ML20204H978
Person / Time
Site: Byron, Braidwood  Constellation icon.png
Issue date: 03/23/1999
From:
COMMONWEALTH EDISON CO.
To:
Shared Package
ML20137D740 List:
References
NUDOCS 9903290228
Download: ML20204H978 (150)


Text

ATTACHMENT E i MARKED.UP PAGES FOR PROPOSED CHANGES BRAIDWOOD STATION REVISED TS PAGES 3.7.15-1 3.7.16 - 1 3.7.16 - 2 3.7.16- 3 3.7.16-4 3.7.16 - 5 3.7.16 - 6 (new) 4.0 - 2 REVISED BASES PAGE_S B 3.7.15-1 through B 3.7.15-7 8 3.7.16-1 through B 3.7.16-8

)

1 l

l i

~

9903290228 990323 PDR ADOCK 05000454 P PDR ,_._,

B-1 )

r: -

Spent Fuel Pool Boron Concentration g 3.7.15 )

l '

i-3.7 PLANT SYSTEMS 3.7.15 Spent Fuel Pool Boron Concentration ,83*//'C#N' I LCO '3.7.15 The spent fuel pool boron. concentration shall be:2 2000 ppr 4 l

' A. k 3coppm' for flolite spent [ vel oolsteraye ,aeks,* and

. . b.  ?. nodoppn fu ZEseph Gat spe fue/ p oo/ d ery s f<e Cs.

APPLICABILITY: Whenever fuel assemblies are stored in the spent fuel pool.

ACTIOKS 1 I

...............................__ ...N0TE-------..---..----...-..-.--...-..-.. l LC0'3.0.3 is not applicable.

1 CONDITION REQUIRED ACTION COMPLETION TIME l

l A. Spent fuel pool boroc A.1 Suspend movement of Immediately concentration not fuel assemblies in within limit. the spent fuel pool .

AND A.2 Initiate action to Immediately restore spent fuel pool boron concentration to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 1

SR 3.7.15.1 LVerify the spent fuel pool boron 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> 3

concentration is within limit. ,

i BRAIDWOOD - UNITS 1 & 2 3.7.15 - 1 Amendment i_

n Spent Fuel Assembly Storage 3.7:16 3.7 PLANT SYSTEMS 3.7.16 Spent Fuel Assembly Storage LCO 3.7.16 Each spent fuel assembly stored in the spent fuel pool sha}:

')

i a5 #f*?l a.

W Region 1 of $$sepL OdC Spenl C ffud ce[Muy f*cUS Have an initial nominal enrichment of s 4.7 weight percent U-235 or satisfy a minimum number of Integral Fuel Burnable Absorbers (IFBAs) for higher initial enrichments up to 5.0 weight percent U-235 to permit storage in any cell l', cation.

v

b. Region 2 [c.sepA Cat .sj)ent Sue! pool Mcf*7L Nell W 4 Have a combination of initial enrichment. burnup. and decay time within the Acceptable Burnup Domain of

{

Figure 3.7.16-1. 3.7.16-2. or 3.7.16-3. as aoplicable for that storage configuration. i

c. Interface Requirements Comply with the Interface Requirements within and between adjacent racks,

/ APPLICABILITY:

Knenever fuel assemblies are stored in the spent fuel pool.

W f d.

ilyies / c/ Mckee sperrt belpool storye. saefcs (Ja vo n n t n lto'd nom o 'uf ce nea 'ck~ e a f & g. c pacenC u ^ 235* to per,+,,t sb.tye. in a ceu /scatiber.

e. Ryem 1 o f th> ftec Jfent fielpool shrg ra cEs Han. o ccoth narlon, c4 ins'cid enrickensd and burnup toit L s'>t tLa Acceftdis h thy .hom 4 cf

. Fg~ ate 3 7. 16 - 4 , "

N BRAIDWOOD - UNfTS 1 & 2 3.7.16 - 1 Amendmen

Spent Fuel Assembly Storage l

3. '16 ACTIONS

........ ............................ NOTE------------------------- '---.-- --

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the A.1 Initiate action to Immediately LCO not met. move the noncomplying fuel assembly into a location which restores compliance.

_A m - -,

l

[olle.w'O 'eguirwee tSTr mt :

e W -

a. n: n,,.,:,,d e,,e,ct,<a c,f 6& I a wnn #

it

& S.0 M oy M p e r ce n t~ V- 23 6",

SURVEILLANCE REQUIREMENTS MD A 4 SURVEILLANCE I FREQUENCY SR 3.7.16.1: Verify b nominalyadministrativemeansthe"/nitial h e Prior to Yfo we. W storing the I Oecced ggg ge, u4sf enrichment' of the fuel assembly is u

re/5(ar 3 '7./4-3. I 54.7weightpercentU-235orgminimum fuel assembly  ;

number of IFBAs. M M -

in Region 1 1 w i& ^less kn the. mihimur s nuo.sherof L'F6AS

_ mp ' ^ ^ f r

-SR 3.7.16.2 Verify by administrative means the :rior.to 'e. sam (,bdic, 'j combination of initial enrichment. burnup, storing the IvffBT 3.7.I4-3. A and decay timesof the fuel assembly is fuel assembly within the Acce'ptable Burn f in Region 2 i

Fi ure 7 16-1, 3.7.16-2, i 3.7.16-3.7.11.-4.

^

Domainoh

'SR 3.7.16.3 Verify by administrative means the Prior to interface requirements within and-between storing the adjacent-racks are met. fuel assembly r//.rd o r 3.?./4-2. 3 in the spent fual pool BRAIDWOOD - UNTTS 1 & 2 3.7.16 - 2 -

Amendment

r INSERT 3.7.16-2.1 .


N OTE -- . - - - -

item a is only applicable for storage of fuel assemblies in Region 1 Holtec spent fuel pool f storage racks. Item b is only applicable for storage of fuel assemblies in Region 1 ,

Joseph Oat spent fuel pool storage racks. j j

INSERT 3.7.16-2.2 NOTE Figures 3.7.16-1, 3.7.16-2, and 3.7.16-3 are only applicable for storage of fuel assemblies in Region 2 Joseph Oat spent fuel pool storage racks. Figure 3.7.16-4 is only applicable for storage of fuel assemblies in Region 2 Holtec spent fuel pool storage ,

racks.

l

. INSERT 3.7.16 2.3


N OTE -

Only applicable for storage of fuel assemblies in Joseph Oat spent fuel pool storage racks.

[J Spent Fuel Assembly Storage 3.7l16 G0000 . . . _ _ _ . . . . _ _ . _ . - . . ._ _ _ _ . .

~~ 9i (m.

' " _.: ~ ~ ~' ~ ~._.1.1 _ ~ E _ _ _ _

~ ~ ^

TDIE:

>
3000- j o YEAlts

,> Y E.\l's 1 ;-)

ACCEI' TABLE YE'\lts

- H.U._R. .N U. I) 'DO.\1AIN M, YEAl?S 45000 ..

7 . . - . _ _ _ . _ _ . , _ . . .. _ _ . .

- . . . . . ~~ L . . l' : _^_: L_~ L 40000 _:

_..f /_ ~ ~ ~ . ' ~ ~ ^

/ ._ _ _ .

R 23I)O00 c ___._

f__ . L. . j_._- -_._...

N n

. a -- . . _ , .. _._;._..__

$: l30000 7.25000

. . . _ j

. - _./ - . _ _ _ _ . . _ _ \

>: 20000 j

= . _ . . f

,c

. __ .4

.. : > O 0 0 if..

- q

c _

r--

4

.0000 . - _

l'NACCEI'TAHLE -

_:. Bl'I<NI:l' D O.\l AIN 5000 i g I l.0 2.0 3.0 4.0 5.0 INITIAL. I ~-235 ENltWII.\ LENT (w/o) 1 Figure 3.7.16;l (page 1 of 1) '

Region 2 All Cell Configuration Bur.nug' ements

( .n,3,f k O f Sf af Gel Al a2/km) snud  :

N BRAIDWOOD UNITS 1 &.2 3.7.16-3 Amendment 9

r-Spent Fuel Assembly Storage 3.7.16

.15000

  • *~

DECAY

<10000 T1.\U"'-

0 YEAUS u._ y - . . . . . . _ . . . . . _ -

5 YEAHS

,..t_._.- . . . . _ . _ _ . . . - _ . . . _ -

_ __ _... ../ 10 YE.\US

_..35000

.._._a_._.. . -

_ _ . . -. . I a i.E,AI6

9. -

ACCEPTABLE -

".; BURNUP . D0.\ LAIN 20 YEARS-i: 30000 l

.._ _ _ , _ I. -

J

s. .

s-. e .

o,,... m,m.-e.... .

n... ~..

72

~

p.,5000 7,, .

>>20000 '

.) -~

/,- --

? '. _.__......

.___.4_... ..4 ... _.._.._ ..

@15000

. .m_

-) - -.

0000 . . ..

I'NACCEPTABLE -

Bl'RN1 P D0.\ LAIN 3000 1

h ws

-4 .

0 1.0 2.0 3.0 '

1.0 5.0 INITIAL l'- 735 ENIUCll.\1ENT (w/o)

Figure 3.7.16-2 (page 1 of 1)

-Region 2 3-out-of-4_ Checkerboard Configuration Burnu Credit Requirements

%wn -

(;&,f k ckf 5f sf L_I Alahla) now BRAIDWOOD - UNITS 1 & 2 3.7.16-4 Amendment

Spent Fuel Asrembly Storage 3.7.16 s

5000

'1000 e.. e . - w. _ ** ,.m.+ -

N ,

[.. .. ._;_. . . . . . . _ . _ _ _ - . __:_._.,___... , . _ . .

n  : -

- l1000 .

g

=y x '

. i ;

/ ,

w

_. _ 7- n l

-!2000

!/

j . . _ _ . . .

14 i ogg-UNACCEl'TA11LE 11UltNUI) DOMAIN

.a . .

- - . . . . ~ _ . . . .

0

1. 0' . 1. 2 . 1.1 4.0 1.8 5.0..

INITI.\L U- ?:15 ENitlCllMENT (w/o)

Figure 3.7.16-3 (page 1 of 1)

Region 2-2-out-of-4 Checkerboard Configuration Burnu Credit Requirements

( ;7bsefL (%.+ 5 n f k_ I % Ix snun' ?ae.ks)

' BRAIDWOOD - UNITS'1 & 2' 3.7.16-5

~ Amendment 4

> Scent Fuel Assec'. 5.t: ags.

. .c 45 & . > > ' '

40600 ' . ,fe.. an 4~

/ A' e '

(S.6,4 poco;i m 35CDD fvRdup '

i..

, , , , e \,

s...-..-

g ACCEPTABLEh0 MAIN N f, M7#*)

$ 3 0600 ~

b

  • ' * (" 2M "d i <*S 25600 e a' W> 2f0fo) .

32 ta x c . ,, y , , ,,g g.,...

gE 20 COO

~=

~

(3,rgygfo)

.7. .N D,.'L<')

~-

  • 15co .

a -(b,tif/0) i u n ce a ri1 & C 10 COO 1.2, u

c

\ Buddup 10mA'd -

(2.f,lC220) 5CC# '

f, w 09)/

%1 (2.,3090) 0 ' ' '

' 7.5 3 3.5 4 4.5 5

N:T:f. ' -23C EN:.:C:-D:ZNT lw/c 4

Region 2 ' ::gure F1 3 .1' '. (page 1 of 1)

-";; r - ;~a; : ca Requirements Fuel Asnbh dunwp

( Holtec Spent fad PoolStage RaeEs) h ot

' o 'J - NITS 1 & 2 3 7.16 M ';

Amendmentk

Design Features 4.0 DESIGN FEATURES (continued) 4.3 Fuel Storage 4.3.1 Criticality Q

.The spent fuel storage racks are designed and shall be maintained with:

a. . Fuel assemblies having a maximum U-235 enrichment of 5.0 weight percent 7, e 4 , J ,,
b. [k,,, < 1.0 if fully flooded with unborated water which includes an allowance for uncertainties as described in WCAP-14416-NP-A. " Westinghouse Spent Fuel Rack Criticality AnalysisMethodology":(,g g 4
c. fk -

s 0.95 if fully floodel wTtliwater borited to 550 ppm.

w$ch includes an allowance for uncertainties as described a

Criticality Analysis Methodology": gg3 p g g'in W

~

d. iAnominal10.32inchnorth-southa west center to center distance between fuel assemblies placed in Region 1 racks: 3nr f

e.

fAnominal9.03inchcentertocenterdistanceMweenfuel assemblies placed in Region 2 racks.

a'inaae The spent fuel pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 423 ft. O inches.

4.3.3 Capacity

{

The spent fuel pool is designed and shal aintained with a  !

storage capacity limited to no more than -2670 fuel assemblie

{

. M 2W4 {

f' f;h listIe< sfk$ SCI'

""Q-fe,[ wa & w kic.h oucl des a n 0'Y'km.1o.yc,ffllhNN"'

fyk i hakal a//ow h 9t H1-u?F20? oe k u~oe bat "CAobeab gg), /2m/d SI E'l* D E'f, i %"I "*-

p <f, t 9 99] a m.aa ! M S7Y 0 e ud,r ',,f k od

b. Q IM k<sjS & "'Qlg,,Q,4 e,,f Y een/ce h e b '"'dsb"ct n ea 44 - 5 *"

' h e f ~ ^' b ' I '

f l

a. n o w ,n a l 7. 9 7 m f 1 h 9L'i$'), 'C$lClM? 6c } y,,,

f eI f. ,u ace] n & p,~

6 ede J ,a<ou Q w 2/m d

x--

BRAIDWOOD - UNITS 1 & 2 4. 0 - 2 Amendment d

Spent Fuel Pool Boron Concentration B 3.7:15 B 3.7 PLANT: SYSTEMS B 3.7.15 Spent Fuel-Pool Baron Concentration I 1

@r I, /Qd

' BASES

_gf , /, >(Yc j BACKGROUND' The. spent fuel pool provides for storage of various Westingh'ouse Optimized Fuel Assembly (OFA) types of different initial fuel enrichments and exposure histories in two distinct regions. (For this discussion, the term 0FA is intended to refer to the specific reduced fuel rodlet diameter. and includes all analyzed fuel types with this .,

%e ee / 8 I Ili'/ / diameter. such as Vantaae 5.)> There are 23 separatetracks which provide placement locations for a total of 2870 new or i used fuel assemblies. Included in this are six specific storage locations in one of the racks for placement of failed fuel assemblies. These locations are identified a fAes the failed fuel storage cells. Of %ef23 racks. four are designated " Region 1." with the remaining 19 racks designated as " Region 2".. The analytical' methodology used to develop the criticality analyses has been reviewed and approved by

psac r b 3.7.1Ct. 2 ', + l Po.I s}*yy %

Regibn 1 radks contain 392 cells which are analyzed for storing Westinghouse.0FAs in an "All Cells" arrangement l (that is, the criticality analysis assumes that spent fuel i

! assemblies reside in all available cell locations with the -

exception of the toundary requirements). The stored fuel assemblies may contain an initial nominal enrichment of

{

s 4.7 weight percent U-235 (without Integral Fuel Burnable 1 Absorbers (IFBAs) installed) up to an initial nominal enrichment of s 5.0 weight percent U-235 provided that the renuirement for a minimum number of 16 IFBAs is met (Ref M) . The IFBAs are required to have, as a minimum, a borun loading of 1.0X. equal to an amount of l 1,5 mg B"/ inch. This is the minimum standard poison material loading offered by Westinghouse for 17X17 0FAs.

Region 2 racks contain 2472 cells which are also analyzed for storing Westinghouse OFAs in a combination' of storage  ;

configurations. These patterns are- '

i

1) "All Cells" Storage: '

.2) "3-out-of-4 Checkerboard" Storage: and  !

3) "2-out-of-4 Checkerboard" Storage.

i i

BRAIDWOOD - UNITS 1 & 2 B 3. 7.15 - 1 Revision [

INSERT B 3.7.15-1.1 in addition, during the installation of Holtec spent fuel pool storage racks, both Holtec and Joseph Oat spent fuel pool racks will be in the spent fuel pool. At the completion of installation, only Holtec spent fuel pool storage racks will be in the spent fuel pool.

INSERT B 3.7.15-1.2 The 23 Joseph Ost spent fuel pool storage racks will be replaced with 24 Holtec spent 3 fuel pool storage racks, which provide placement locations for a total of 2984 new or used fuel assemblies. Of the 24 Holtec spent fuel pool storage racks, four are designated " Region 1" with the remaining 20 racks designated as " Region 2." The analytical methodology used for the criticality analyses is in accordance with established NRC guidelines (Ref. 2).

e l

l I

J

Ik ,

Spent Fuel Pool Boron Concentration

~

. R 3. 7.1'5 BASES-BACKGROUND ~(continued) 7 .

For the "All-Cells" storage configuration.-the stored fuel assemblies may.contain an initial nominal enrichment of 5 1.14 weight percent U-235 (without taking credit for fuel burnup or radioactive-decay of fuel constituents) up to an initial nominal enrichment of s 5.0 weight percent U-235, when fuel burnup and radioactive decay of fuel constituents are credited.

For the "3-out-of-4 Checkerboard" storage configuration, the -

stored fuel assemblies may contain an initial nominal enrichment of.s 1.64 weight percent U-235 (without taking credit for fuel burnup or radioactive decay of fuel constituents) up to an initial nominal enrichment of s 5.0 weight percent U-235, when fuel burnup and radioattive decay of fuel constituents are credited. In this storage pattern.

there can be no more than three stored assembli'es in any 2X2 matrix of cell lattices.

For the "2-out-of-4 Checkerboard" storage configuration, the stored fuel assemblies may contain an 1aitial nominal enrichment of 5 4.10 wei credit for fuel burnup) ght up percent U 235 to an initial (without nominal taking enrichment of s 5.0 weight percent U-235. when fuel burnup is credited.

In.th'is storage pattern. no two fuel assemblies may be f y,.-

, /g 3,e 7 g.2. /

stored " face adjacent" (that is there must be an empty cell opposite each face of the fuel assembly).

The water in the spent fuel pool normally contains soluble boron which results in large subtriticality margins under actual operating conditions.

=

BRAIDWOODL- UNITS 1 &'2 B 3.7.15 - 2 9

Revision [

a

INSERT B 3.7.15-2.1 Holtec Soent Fuel Pool Storaoe Racks Region 1 racks contain 396 cells which are analyzed for storing Westinghouse OFAs in an "All Cells" arrangement (that is, the criticality analysis assumes that spent fuel assemblies reside in all available cell locations). The stored fuel assemblies may.

contain an initial nominal enrichment of s 5.0 weight percent U-235 (with or without Integral Fuel Bumable Absorbers (IFBAs) installed) (Ref. 4).

Region 2 racks contain 2588 cells which are also analyzed for storing Westinghouse OFAs in an "All Cells" arrangement (that is, the criticality analysis assumes that spent fuel assemblies reside in al' available cell locations). For the "All Cells" storage configuration, the stored fuel assemblies may contain an initial nominal enrichment of s 5.0 weight percent U-235 with credit for bumup.

l 1

I l

r Spent Fuel Pool Boron Concentration B 3.7.15 BASES APPLICABLE

' SAFETY ANALYSES criticality analyses NRC approved methodolo Ref. 1)r Th (gies1 handling wereged accident to develo naly.ses are.revided in Reference The accident analyses for ftc. fasep4 Ost- or criticality and spent fuel poo lution are rovided 1 sf w t fue/ f ,, t . Reference '=d' respectively. (for de. . rosea c.c.q.e.it Le/

u struseradoas )

Jf###J F"*E' .The critica ses for the spen ue assemb y storage racks confirm that k,,, remains < 1.Os(including es c/i uncertainties and tolerances) at a.95% probability with a 95% confidence level (95/95 basis). based on the accident condition of the pool being flooded with unborated water.

. s for Me. $sefk Gstsg4 Thus, the design of both regions assumes the use of k fu<.( f#,I st,nJe rg unborated water while maintaining stored fuel in a subtritical condition.

Q nd S cM, loe the hlice-Jfcnt lue/ "oc/

A JestaJo 'However, the presence of soluble boron has been credited to f*'D provide adequate safety margin to maintain spent fuel assembly storage rack k,y s 0.95 (also on a 95/95 basis) for all postulated accident scenarios involving dropped or

.U#/ 6'# //o/te '~/ misl aded fuel ssemblies and loss of spent fuel pool emperature control. Crediting the presence of soluble Sp4 ont 3pe.st (udgoc/ oron for mitigation of these scenarios is acceptable based N## #" I"g /i on applying the " double contingency principle" which states that there is no requirement to assume two unlikely, independent, concurrent event to en ure protection against (f e the JEseph Oat' a criticality accident (Refs. 'i,ana %).

s0est (vd 0wf stenJc-The accident analyses address the fo lowing five postulated fd 5 D ) scenarios:

1) fuel
2) fuel. assembly dropbetween assembly drop on top of rackrack:

modules:

3) fuel assembly drop between rack modules and spent fuel pool wall:
4) change in spent fuel pool water temperature: and
5) fuel assembly loaded contrary to placement restrictions.

Of these, only the last two have the capacity to increase reactivity beyond the analyzed condition jf

~r Ic. thWpt. 6 tur spwf luelpor a fonye. racks, ad og seer >*c s 2,3,& C hae & eqcky te lacreast res e bm ty for fu (jettae spe,,t (Let po/ s6tg neto, BRAIDWOOD - UNITS 1 & 2 B 3.7.15 - 3 Revision [

INEERT B 3.7.15-3.1 and methodologies in acconiance with established NRC Quidelines were used to develop the criticality analyses (Ref. 2) for the Holtec spent fuel pool storage racks g-- . .. . . . .

m Spent Fuel Pool Boron Concentration B 3.7.15 mfk~ W f N'I N ' *f "" b BASES 3 ~

J

~

APPLICABLE SAFETY ANALYSES (continued)

Calculations were performed to determine the reactivity change caused by a change in spent fuel pool water temperature outside the normal range (50 - 160 F). For the change in spent fuel pool water temperature accident. a temperature range of 32 - 240 F is considered. In all cases. additional reactivity margin is available to the  !

0.95 kg, limit to allow for temperature accidents. The 1 temperature change accident can occur at any time during gy,,, f 3 3,7./r- 4. / operation of the spent fuel pool.

For the fuel assembly misload accident, calculations were performed to show the largest reactivity increase caused by i a Westinghouse 17X17 0FA fuel assembly misplaced into a l G-ran/ S 3.7./r -4. 2. storage cell for which the restrictions on location, enrichment, or burnuo are not satisfied 4 The assembly @St b 1j misload accident can only occur during fuel handling i operations in the spent fuel pool.

For the above postulated accident conditions, the double contingency principle can be applied. Specifically. the 4 g @3eI([ N. presence of soluble boron in the spent fuel pool water can sp f b j f** be assumed as a realistic initial condition since not assuming its presence would be a second unlikely event,

'gg,de M i j TJfpentfuelpoolsolubleboronhasbeencreditedinthe criticality safety analysis to offset storage rack and fuel assembly tolerances, calculational uncertainties, uncertainty associated with burnup credit and the reactivity )

g,, f 8 3. 7./f- %3 nreasecausedbypostulatedaccidentconditions.f Based on the above discussioni should a spent fuel pool l water temperature change accident or a fuel assembly misload  !

accident occur in the Region 1. Region 2. or failed fuel h & @Sf l

storage cells, kg, will be maintained s to 0.95 due to the Y g fy/

r I

7 presence of at least 550 ppm (no fuel handling) or 1650 ppm (during fuel handling) of soluble boron in the spent fuel g)e Ms poolwater.7 '

3 , s es 3. v.< r - v. y l

BRAIDWOOD - UN1'TS 1 & 2 B 3. 7.15 - 4 Revision L

L

INSERT B 3.7.15-4.1 Calculations were also performed, for the Holtec spent fuel pool storage racks, for a j spent tuel pool temperature of 4*C (3g*F) which is well below the lowest normal '

operating temperature (50*F). Because the temperature coefficient of reactivity in the spent fuel pool is negative, temperatures greater than 4*C will result in a decrease in reactivity. {

1 INSERT B 3.7.15-4.2 Calculations were also performed to show the largest reactivity increase caused by a Westinghouse 17X17 OFA fuel assembly misplaced into a Holtec Region 2 storage cell for which the restrictions on enrichment or bumup are not satisfied.

1 INSERT B 3.7.15 4.3 For the Holtec spent fuel pool storage racks, spent fuel pool soluble boron has been credited in the criticality safety analysis to offset the reactivity caused by postulated accident conditions. Because the Region 1 racks are designed for the storage of fresh fuel assemblies, a fuel assembly misload accident has no consequences from a criticality standpoint (i.e., the acceptance criteria for storage are satisfied by all assemblies in the spent fuel pool).

INSERT B 3.7.15 4.4 For the Holtec spent fuel pool storage racks, should a fuel assembly mistoad accident occur in the Region 2 storage cells, keff will be maintained s 0.95 due to the presence of at least 300 ppm of soluble boron in the spent fuel pool water.

1

4 Spent Fuel Pool Boron Concentration B 3.7.15 l

.. l BASES APPLICABLE SAFETY ANALYSES (continued) p/ spent fuel pool dilution analys1 g 4 4'f , ye ef.

f has been jL performed as required by Reference The analysis assumes spwt 6d ol an initial baron concentration of 2 ppm. The dilut,on analysis concludes that an unplanned or inadvertent event Jfored</ekt> that would result in the dilution of the spent fuel pool boron concentration from 2000 ppm to 550 ppm (minimum non-accident boron concentration) is not credible.

/

N 7 (f e gc g, g, gg Interface recuirements;have been established to ensure kg, 1s maintainec within the appropriate limits. There are

, Spent 6c/ ,,/ f(c/cyc interface requirements between Region I racks between gog ,, Region 1 and Region 2 racks, between Region 2 racks, and within racks between different checkerboard configurations.

These requirements are necessary to account for unique geometries and configurations which exist at the interfaces.

Interface requirements exist between adjacent ' racks to account for the potential reactivity increase in 3-out-of-4 and 2-out-of-4 storage configurations along the interface with non-aligned racks.

The concentration of dissolved boron in the spent fuel pool satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The spent fuel pool boron concentration is require

' 2 3cc f m ter H,e /(c/de 2 2000 ppm. The specified concentration of dissolved boron b f(".I ' l 5'd in the spent fuel pool preserves the assumptions used in the 3c,gea and

/ St *f *' analyses of the potential critical accident scenarios as described in References 2. 3. :nd 4F .: conccntrat Or cf l dis:chcd b0rcr is the minimum required concentration for '

fuel assembly storage and movement within the spent fuel ht tI' hefEC'C'f'"$ 'poo . =

t l (uct gcd s tc <'aye. ra ck1,  % da.ncideIkoim

, oi,lc , hi< the he cats 1 e,t Meentreh'm ef 2cco ff ^

SudfcolS bye cae S

.TNSCAT 6 3.7.lf-f.I i BRAIDWOOD - UNITS 1 & 2 8 3.7.15 - 5 Revision

]

I INSERT B 3.7.15-5.1 The dissolved boron concentration of 300 ppm bounds the minimum required concentration for accidents occurring during fuel assembly movement within the spent fuel pool for the Holtac spent fuel pool storage racks.. During installation of the Holtec spent fuel pool storage racks, when both Joseph Oat and Holtec spent fuel pool storage I racks are in the spent fuel pool, the more restrictive of the two minimum boron concentration limits (i.e.,2000 ppm) is required to be met. After removal of all Joseph -

Oat spent fuel pool storage racks, only the 300 ppm boron concentration limit is required to be met.

r Spent Fuel Pool Boron Concentration B 3.7c15 BASES APPLICABILITY This LC0 applies wh never fuel assemblies are stored in the spent fuel pool.

(FuJm ACd pfM/A,*p M e d The presence of soluble boron '1 vanour con:cgtr; tion:) 1s assumed in the criticality analyses and is credited for

, ensuring that spent fuel pool k will be maintained s 0.95 ace.'Jeuf coo 4,rts,es aaJ t a 95% confidence level for aYiestorage configurations.

The 2000 ppm minimum Doron concentration is also an initial i condition in the spent fuel pool dilution analysisr Therefore, the restriction on soluble boron concentration in the spent fuel pool water must be maintained at all times when fuel assemblies are stored in the soent fuel pool. l V egli ACTIONS The ACTIONS have been modified by a Note indicating that LC0 3.0.3 does not apply.

A.1 and A.2 When the concentration of boron in the spent fuel pool is less than required, immediate action must be taken to preclude the occurrence of an accident or to mitigate the consequences of an accident in progress. This is most efficiently achieved by immediately suspending the movement of fuel assemblies. This does not preclude movement of a fuel assembly to a safe position. Immediate actions are i l _ take to restore spent fuel pool boron concentrati '

4.VVU p pmi .

If moving fuel assemblies while in MODE 5 or 6. LC0 3.0.3 would not specify any action. If moving fuel assemblies while in MODES 1. 2. 3. and 4. the fuel. movement is independent of reactor operations. Therefore, inability to suspend movement of fuel assemblies is not sufficient reason to require a reactor shutdown.

BRAIDWOOD - UNITS 1 & 2 8 3.7.15 - 6 Revisio

Spent Fuel Pool Boron Concentration B 3.7.15

' BASES SURVEILLANCE SR 3.7.15.1' REQUIREMENTS This SR verifies that the concentration of boron in the-spent fuel pool is within the required limit. As long as this SR is met, the analyzed accidents are fully addressed.

E,e,. / f6 3. 7/f-7./ . ,

The hour f equenc is appr priat based o opera ng exp ience a d beca se sign' icant hanges the oron co centrati n in e spent uel-p 1 are d'fficul to

, p oduce w' hout' tection consi ering t larga volume ater co ained n'the ent f 1 pool. An an ysis ha conclu d that a spent uel p 1 boron iluti event i suffi ent ma nitude redu boron oncent ation be ow th -

mini m non- ccident requir ent is ot cre ible (R . 4). '

4 REFERENCES 1. WCAP-14416-NP-A " Westinghouse Spent Fuel Rack l Criticality Analysis Methodology " Rev.1. dated 3 3, 7, g 7. govember,1996.

O3g. CAC-97-162 " Byron and Braidwood Spent Fuel Rack Criticality Analysis Using Soluble Boron Credit."

Escar M 3. 7./(-7.3 dated Mayi 1997.

UFSAR., Section 15.7.4.

l g A. " Byron /Braidwood Spent Fuel Pool Dilution Analysis."

, Rev. 3, dated June 17. 1997. .

I

7E Double contingency principle of ANSI N16.1 - 1975, as l specified in the April 14, 1978 NRC letter (Section 1.2) and implied in the proposed revision to l Regulatory Guide .1.13 (Section 1.4, Appendix A).

ANSI /ANS 8.1 - 1983 "American National Standard for l Nuclear Criticality Safety in Operations with Fissionable Materials Outside Reactors."

O' 9 I.Safety Evaluation Report (SER) dated October 25. 1996, issued by the Office of Nuclear Reactor Regulation for Topical Report WCAP-14416-NP-A " Westinghouse Spent Fuel Rack Criticality Analysis Methodology."

l BRAIDWOOD - UNI'TS l'& 2. B 3.7.15 - 7 Revisio

INSERT B 3.7.15-7.1 .

The 7 day frequency is appropriate based on operating experience and takes into consideration that no major replenishment of pool water is expected to occur over such a

{

j short period of time.

I INSERT B 3.7.15-7.2 l

I

2. NRC Memorandum from L Kopp to T. Collins, dated August 19,1998, " Guidance 1 on the Regulatory Requirements for Criticality Analysis of Fuel Storage at Light j Water Reactor Power Plants." l lNSERT B 3.7.15-7.3 i
4. Holtec International Report, HI-982094, " Criticality Analysis for the Byron /Braidwood Rack Installation Project," Project No. 80944,1998.

}

Spent Fuel Assembly Storage B 3.7.~16 8 3.7 PLANT SYSTEMS

.B 3'.7.16 . Spent' Fuel' Assembly Storage BASES G k Gd~

BACKGROUND The spent fuel pool provides for storage of various Westinghouse Optimized Fuel Assembly (OFA) types of ,f[r h/of.

different initial fuel enrichments and exposure histories in two distinct regions. (For this discussion the term 0FA is SEy' intended to refer to the specific reduced fuel rodlet ysdf /3 3 l/5'-/./

diameter, and includes all analyzed fuel types with thi m diameter, such as Vantage 5.)3 There are 23 separate racks which provide placement locations for a total of 2870 new or .

used fuel assemblies. Included in this are six specific storage locations in one of the racks for placement of g failed fuel assemblies. These locations are identified as f4ne

~ the failed fuel storage ce;ls. Of 4he*23 racks, tour are designate " Region 1" with the remaining 19 racks designated as " Region 2" The analytical methodology used to develop ys ee f /3 3. 7. /r-/.2. the criticaLv analyses has been reviewed and approved by the NRC (Ref. 1)?

r., a c.) 5,w + L / Ibol 5-),aya Ta.fa Regiori 1 racks'contain 392 cells which are analyzed # 0r storing Westinghouse OFAs in an "All Cells" arrangement (that is, the criticality analysis assumes that spent fuel assemblies reside in all available cell locations, with the exception of the boundary requirements) The stored fuel assemblies may contain an initial nominal enrichment of s 4.7 weight percent U-235 (without Integral Fuel Burnable Absorbers (IFBAs) installed) up to an initial nominal .

enrichment of s 5.0 weight percent U-235, provided that the 3 irement for a minimum number of 16 :FBAs is met (Ref. e). The IFBAs are required to L . e. as a minimum, a boron loading of 1.0X. equal to an amount of l'.5 mg B"/ inch. This is the minimum standard poison mate' rial loadino offered by Westinghouse for 17X17 0FAs.

Region 2 racks contain 2472 cells whth are also analyzed for storing Westinghouse OFAs in e 'ombination of storage configurations. These patterns are:

1) "All Cells" Storage:
2) "3-out-of-4 Checkerboard" Storage: and
3) "2-out-of-4 Checkerboard" Storage.

BRAIDWOOD UNITS 1 & 2 B 3. 7.16 - 1 Revisio e

i INSERT B 3.7.15-1.1 in addition, during the installation of Holtee spent fuel pool storage racks, both Holtec and Joseph Ost spent fuel pool racks will be in the spent fuel pool. At the completion of I installation, only Holtec spent fuoi pool storage racks will be in the spent fuel pool. I INSERT B 3.7.15-1.2 The 23 Joseph Ost spent fuel pool storage racks will be replaced with 24 Holtec spent fuel pool storage racks, which provide placement locations for a total of 2984 new or used fuel assemblies. Of the 24 Holtee spent fuel pool storage racks, four are designated " Region 1" with the remaining 20 racks designated as " Region 2." The '

analytical methodology used for the criticality analyses is in accordance with established NRC guidelines (Ref. 2).

i

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Spent Fuel Assembly Storage B 3.7.16

]

i

. CASES; .

j

' BACKGROUND (continued);

For the ~"All Cells" storage configuration, the stored fuel assemblies may contain an initial nominal enrichment of j s 1.14 weight percent U-235 (without taking credit for fuel 1

burnup or radioactive decay of fuei constituents) up to an 4

. initial. nominal enrichment of 5 5.0 weight percent U-235.

when' fuel burnup and radioactive decay of fuel constituents l are credited.

]

For the "3-out-of-4 Checkerboard" storage configuration, the stored fuel assemblies may contain an initial nominal

{

enrichment of s 1.64 weight percent U-235 (without taking credit for fuel burnup or radioactive decay of fuel j constituents) up to an initial nominal enrichment of s 5.0 (

weight percent U-235, when fuel burnup and radioactive' decay of fuel constituents are credited. In this storage pattern.

there can be no more than three stored assemblies in any 2X2 i matrix of cell lattices.

For the "2-out-of-4 Checkerboard" storage configuration, the stored fuel assemblies may contain an initial nomina.1 enrichment of s 4.10 weight percent U-235 (without taking

{

credit for fuel burnup) up to an initial nominal enrichment l!

of s 5.0 weight percent U-235, when fuel burnup.is credited.

In this storage pattern, no two fuel assemblies may be stored " face adjacent" (that is, there must be-an empty cell opposite each_ face of the-fuel assembly).

)

If a f 6 3. 7. h"-2.)

The water in the spent fuel pool normally contains soluble boron ~ which results in large subcriticality margins under

actual operating conditions.

l l

l BRAIDWOOD'-LUNITS 1 &-2 B 3. 7.16 - 2 Revision /

l L

o

' INSERT B 3.7.15 2.1 Holtec Spent Fuel Pool Storace Racks l

l Region 1 racks contain 396 cells which are analyzed for storing Westinghouse OFAs in

, an "All Cells" arrangement (that is, the criticality analysis assumes that spent fuel i

assemblies reside in all available cell locations). The stored fuel assemblies may contain an initial nominal enrichment of s 5.0 weight percent U-235 (with or without

! Integral Fuel Bumable Absorbers (IFBAs) installed) (Ref. 4).

Region 2 racks contain 2588 cells which are also analyzed for storing Westinghouse OFAs in an "All Cells" arrangement (tnat is, the criticality analysis assumes that t cent fuel assemblies reside in all available cell locations). For the "All Cells" storage configuration, the stored fuel assemblies may contain an initial nominal enrichment of s 5.0 weight percent U-235 with credit for bumup.

I I

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7 Spent Fuel Assembly Storage B 3.7.16 BASES

~

APPLICABLE NRC approved methodologies wer r~EU Eds 8 5.W-LC SAFETY ANALYSES criticality analyses (Ref. Ik[e used Th fuel to oevelop handling acc1 centthe nalyses are pc w ded in Reference The at:1 dent analyses for fle, foseph Caf or critical,ity and spent fuel poo lution are proviaed w Reference " :"'d ^ . respective 1y.

s?a t Sue / PooI u (foe the.

stw.y ra.ro$uoaj)k c.c seca fuel Jf'"fc reek' The critica ana yses for the spent ue assembly storage rack's confirm that k,o remains < 1.02(including e3cn. uncertainties anc tolerances) at a 95% probability with a 95% confidence level (95/95 basis), based on the accident y condition of the pool being flooded with unborated water.

f s for f4c. 6 4 Ods f Thus, the design of both regions assumes the use of

( fa< f goal Wehje #, /***pdtwater while maintaining stored fuel in a unborated subcritical condition.

c sd & cM, for the bltec-sfcne fue/0os/ Jeg@ However. the presence of soluble boron has been credited to f**D provide adequate safety margin to maintain spent fuel assembly storage rack k m s 0.95 (also on a 95/95 basis) for all postulated accident scenarios involving dropped or g g misloaded fuel assembliesand loss of spent fuel pool emperature control. Crediting the presence of soluble Lg ont Jf ent 6dge/ oron for mitigation of these scenarios is acceptable based ggyfe. pers) on applying the " double contingency principle" which states that there is no requirement to assume two unlikely, independent, concurrent event to en ure protection against (6et4cJisefeOat'l a criticality accident (Refs. % and1ii).

The accident analyses address the fo lowing five postulated s8est

/'d5 hha 0)wt sto. Jc-scenarios:

1) fuel assembly drop on top of rack:
2) fuel assembly drop between rack modules:
3) fuel assembly drop between rack modules and spent fuel pool wall:
4) change in spent fuel pool water temperature: and
5) fuel assembly loaded contrary to placement restrictions.

Of these. only the last two have the capacity to increase l reactivity beyond the analyzed condition jp N

les Ntis Eup t bat spe t fueljyof aforsje. reeks ando scen Wo.r 2,3,& S~ han He.eqch it Increase rese M, oh for W Nortec .sper.t &c( \

pcol ststys (self.1 t . .-

l BRAIDWOOD - UNITS 1 & 2 B 3.7.16 - 3 Revision 0

)

l lNSERT B 3.7.15-3.1 and methodologies in accordance with established NRC guidelines were used to develop the criticality analyses (Ref. 2) for the Holtec spent fuel pool storage racks

\

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e 9

c.

Spent Fuel Assembly Storage B 3.7 '

BASES 3 b *

"f

  • s Lu,e &#

N APPLICABLE SAFETY ANALYSES (continued)  % #

Calculations were performed o determine the reactivity change caused by a change in spent fuel pool water temperature outside the normal range (50 - 160*F). For the change in spent fuel pool water temperature accident, a temperature range of 32 - 240'F is considered. In all cases, additional reactivity margin is available to the 0.95 k,rr limit to allow for temperature accidents. The

= -

temperature change accident can occur at any time during y,/ B 3. 7 / r.y. / operation of the spent fuel pool.

For the fuel assembly misload accident. calculations were performed to show the largest reactivity increase caused by storage cell for which the a Westinghouse restrictions 17X17 0FA on fuel location, assemblyl mispla enrichment, or burnup are not satisfied The assembly l misload accident can only occur durin uel handling gaf B 3.76- V. 2 operations in the spent fuel pool.

For the above po,ulated accident conditions. the double contingency princi le can be a) plied. S ecifically, the

_ 3resence of solubl boron in tie spent f el pool water can l Q de 4MPfN Je assumed as a realistic initial condition since not I 744/

y e r

/ suming its presence would be a second unlikely event.

ent fuel pool soluble boron has been credited in the criticality safety analysis to offset storage rack and fuel assembly tolerances, calculational uncertainties.

uncertainty associated with burnup credit and the reactivity increase caused by postulated accident conditionsj frar R 3. 'lX-V.3 Based on t above discussion! should a spent fuel pool r emperature change accident or a fuel assembly misload a e g (f g-/ accident occur in the Region 1. Region 2. or failed fuel storage cells, k,rr will be maintained s to 0.95 due to the y  % f At l e/ presence of at least 550 ppm (no fuel handling) or 1650 ppm (during fuel handling) of soluble boron in the spent fuel 5 pool water.

Zud R L 7df--9'y 1

i i i BRAIDWOOD - UNITS 1 & 2 B 3. 7,16 - 4 Revision

INSERT B 3.7.15 4.1 Calculations were also performed, for the Holtec spent fuel pool storage racks, for a spent fuel pool temperature of 4*C (39'F) which is well below the lowest normal operating temperature (50*F). Because the temperature coefficient of reactivity in the spent fuel pool is negative, temperatures greater than 4*C will result in a decrease in

, reactivity.

INSERT B 3.7.15-4.2 o Calculations were also performed to show the largest reactivity increase caused by a Westinghouse 17X17 OFA fuel assembly misplaced into a Holtec Region 2 storage cell for which the restrictions on enrichment or bumup are not satisfied.

INSERT B 3.7.15-4.3 For the Holtec spent fuel pool storage racks, spent fuel pool soluble boron has been credited in the criticality safety analysis to offset the reactivity caused by postulated accident conditions. Becausa the Region 1 racks are designed for the storage of fresh fuel assemblies, a fuel assembly misload accident has no consequences from a criticality standpoint (i.e., the acceptance criteria for storage are satisfied by all

  • ( amblies in the spent fuel pool).

INSERT B 3.7.15-4.4 For the Holtec spent fuel pool storage racks, should a fuel assembly mistoad accident occur in the Region 2 storage cells, keff will be maintained s 0.95 due to the presence of at least 300 ppm of soluble boron in the spent fuel pool water.

4 9

t ._

p ,

Spent Fuel Assembly Storage B 3.7.-16 BASES A @ FETY ANALYSES (continued)

Cd spent fuel pool, dilution analys' ef.'4) has been 4yp.[gf g6f 767I( j [performedasrequiredbyReferenc The nalysis assumes f* an initial boron concentration of ppm. The dilution I> f^^7 g,> analysis concludes that an unplanned or inadvertent event that would result in the dilution of the spent fuel pool boron concentration from 2000 ppm to 550 ppm (minimum non-accident boron concentration) is not credible.

Interface rea'tirements3have been established to ensure k,,,

-- 1s maintained-within the appropriate limits. There are

('g d No];

S interface requirements between Region 1 racks, between Region 1 and Region 2 racks, between Region 2 racks, and JOd7[]*Ig/

/ ,a e within racks between different checkerboard configurations.

These requirements are necessary to account for unique g geometries and configurations which exist at the interfaces.

fw/c3 " J Interface requirements exist between adjacent racks to f account for the potential reactivity increase in 3-out-of-4 l and 2-out-of-4 storage configurations along the interface with non-aligned racks. )j

(

The configuration of fuel assemblies in the spent fuel pool {

satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii). H LCO The restrictions on the placement of fuel assemblies within the spent fuel pool in accordance with the requirements in LEr/6 J/dep4 # Jpent the accompanying LC0 ensure that the k,,, of the spent fuel

%fpn/s(c.getacks,ud pool will always remain < 1.0 assuming the pool is flooded )

l 6cM anumg #c p ,/ with unborated water and s 0.95 assuming the presence of )

. is (4cdu' vM u 6,uril 550ppmsolubleboroninthepooj.

R4rce (cr fAc N,//ec spent /nLCOFigures3.7.16-1and3.7.16-2.theAcceptableBurnup I

.f6cI E,/ d,fUc/,rks Domain lies on, above, and to the left of the decay time line applicable to the fuel assembly to be stored. The decay time for that assembly is measured from the time since di the assembly was last discharged.

'.fud poo/ stcpe- / vat /nLC0 Figure 3.716-3.theAcceptableBurnupDomainandthe Unacceptable Burnup Domain are separated by a single line because decay time is not credited in the 2-out-of-4 Forth Scg (<.t ye4 Checkerboard storage configuration. The Acceptable Burnup Domain lies on. abo: and to the left of the line.

hd p/ 46,3c ta'kf, i

BRAIDWOOD - UNI'TS 1 & 2 B 3. 7.16 - 5 Revisio

.\

Spent Fuel Assembly Storage B 3.7.16 BASES LCO (continued)

In each figure the use of linear interpolation between minimum burnups is acceptable.

APPLICABILITY This LCO applies whenever fuel assemblies are storec in tne spent fuel pool.

l ACTIONS The ACTIONS have been modified by a Note indicating that

.- LCO 3.0.3 does not apply.

(Esr fic (Mtee spedGd i put sto.'y luets, a Lov /5' When the configuration of fuel assemblies stored in the J u ro 3. '7. /P '/ 4 '

spent fuel pool is not in accordance with the requirements decepa6/* dunug 3om",'l of the LCO. immediate action must be taken to make the

//ef on,46tto. cud 6 & necessary fuel assembly movement (s) to bring the e

configuration into compliance.

Icit el 1 % bur..sp vzuus ene e4.nent /m.o. If movinc fuel assemblies while in MODE 5 or 6. LCO 3.0.3 would not specify any action. If moving fuel assemblies while in MODES 1. 2. 3. and 4. the fuel movement is independent of reactor operations. Therefore. inability to suspend movement of fuel assemblies is not sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 37161 REQUIREMENTS < "5 '8 fs f h, m& 4- performedvprior to storing the fuel assemb y

-h Eqr d 3. 9. /c - r, . / f in the intended spent fuel pool storage location The

_ ss frequency is appropriate because compliance with the SR i

ensures tnat the relationship between the fuel assembly and I

lts storage location will meet the requirements of the LCO and preserve tne assumptions of the analyses.

This SR ver1fles by aoministrative means that the initial 1 nominal enrltnment of the fuel assembly or a minimum number i of 16 IFBAsals met to ensure that the assumptions of the t

.' 7 safety analyses are preserved. e /m-C

'nev (3ie bcd Hoffcc aJ 3;sep& cd spen w kp ca :p ns~

y , ,

g" I

\ dstoyvtacLsef.)_

f "I

  • W"f "' W vv BRAIDWOOD - UNI'TS 1 & 2 B 3.7.16 - 6 Revision

f; \

l 1

I I INSERT B 3.7.16-6.1 SR 3.7.16.1 has been modified by a Note indicating that item a is only applicable for l storage of fuel assemblies in Region 1 Holtec spent fuel pool storage racks, and item b

!- is only applicable for storage of fuel assemblies in Region 1 Joseph Oat spent fuel pool

- storage racks.

l i

7:

Spent. Fuel' Assembly Storace B 3.7.16 BASES SURVEILLANCE-REQUIREMENTS (continued)-

SR 3.7.16.2-SR 3.7.16.2 is performed prior to storing the fuel assembly in the intended spent fuel pool The frequency is appropriate becaus. storage location.

e compliance with the SR ensures that the relationship between the fuel assembly and

.its storage -location will meet the requirements of the LCO and preserve the assumptions of the analyses.

/g/,,

-This SR verifies by administrative means that the

  1. combination of initial enrichment, burnup. and decay tim of j

/

M3#g 3 J.7/071 the fuel assembly is within the' Acceptable Burnup Domain-of {

Figure 3.7.16-1., 3.7.16-2. 3.7.16-3 for the intended  :

storage configuration to e@nsure that the assumptions of the  ;

saf

% ety analyses are preserved.

SR 3l7.16.3 J eie 3.1.16 Li SR 3.7.16.3 is performed prior to storing the fuel assembly in the intended spent fuel pool storage location. The frequency is appropriate because compliance with the SR {

' ensures that the relationship between the fuel assembly and i its storage location.will meet the requirements of the LCO  !

and preserve the assumptions of the analyses '

3,4 B 1 '7.K-1. 2 This SR verifies by administrative means that the interface requirements (Ref. 2) within and between adjacent racks are j

. met to, ensure that the assumptions of the safety analyses are preserved.

I I

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BRAIDWOOD - UNITS 1 & 2 B 3.7.16 - 7 Revision 4

no l INSERT B 3.7.16-7.1 I SR 3.7.16.2 has been modified by a Note indicating that Figures 3.7.16-1,3.7.16-2, and 3.7.16-3 are only applicable for storage of fuel assemblies in Region 2 Joseph Oat spent fuel pool storage racks, and Figure 3.7.16-4 is only applicable for storage of fuel assemblies in Region 2 Holtec spent fuel pool storage racks. I i

INSERT B 3.7.16-7.2 I SR 3.7.16.3 has been modified by a Note indicating that this SR is only applicable for storage of fuel assemblies in Joseph Oat spent fuel pool storage racks.

l i

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3 I

)

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4 i

j

E

. Spent Fuel Assembly Storage B 3.7.16 BASES REFERENCES 1. WCAP-14416-NP-A " Westinghouse Spent Fuel Rack Criticality- Analysis Methodology." Rev.1. dated h f A 3 7. /g.7.2 _ November. 1996.

JJ CAC-97-162 " Byron and Braidwood Spent Fuel Rack Criticality Analysis Using Soluble Boron Credit."

dated May.1997.

j 3 3,9,jg 7,g UFSAR. Section 15.7.4.

4 " Byron /Braidwood Spent Fuel Pool Dilution Analysis."

Rev. 3. dated June 17, 1997.

Double contingency principle of ANSI N16.1 - 1975, as specified in the April 14. 1978 NRC letter (Section 1.2) and implied in the proposed revision to Regulatory Guide 1.13 (Section 1.4 Appendix A).

ANSI /ANS 8.1 - 1983 "American National Standard for Nuclear Criticality Safety in Operations with Fissionable Materials Outside Reactors."

09/ Safety Evaluation Report (SER) dated October 25. 1996, issued by the Office of Nuclear Reactor Regulation for Topical Repc; t WCAP-14416-NP-A " Westinghouse Spent Fuel Rack Criticality Anal, sis Met adology."

l l

i 4

BRAIDWOOD - UNITS 1 & 2 B 3.7.16- 8 Revision 0-

INSERT B 3.7.15-7.2

2. NRC Memorandum from L. Kopp to T. Collins, dated August 19,1998, " Guidance on the Regulatory Requirements for Criticality Analysis of Fuel Storage at Light Water Reactor Power Plants."

l INSERT B 3.7.15-7.3

4. Holtec Intemational Report, HI-982094, " Criticality Analysis for the Byron /Braidwood Rack Installation Project," Project No. 80944,1998.

1 i

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ATTACHMENT B-2 MARKED-UP PAGES FOR PROPOSED CHANGES BYRON STATION REVISED PAGES 3.7.15-1 3.7.16-1 3.7.16- 2 3.7.16 - 3 3.7.16 -4 3.7'.16 - 5 3.7.16 - 6 (new) 4.0 - 2 REVISED BASE! PAGES B 3.7.15-1 through B 3.7.15-7 B 3.7.16-1 through B 3.7.16-8 t

B-2

e Spent Fuel Pool Boron Concentration 3.7.15 37 ?LANT SYSTEMS 3.7 15 S' pent Fuel Pool Boron Concentration e "# */7 '

w

-LCO 3.7,15 The spent. fuel _ pool boron concentration shall be: 2 2000' ppm

a. k 3coppm foe tip/ba spent fuel oolstorye caeks; and f
b. s. nocoppn he $seph Gat spent fac/ fool dorsfs Ml~s.

APPLICABILITY: Whenever fuel ar,semblies are stored in the spent fuel pool.

. ACTIONS j

.....................................NCTE-------- ----------------------------

LC0 3.0.3 is not applicable'.

+1 CONDITION RF.0VIR'.D ACTION COMPLETION TIME A. Spent fuel pool boroa A.1 Suspend movement of Immediately concentration not ?uel assemblies in within limit. the spent fuel pool.

AND' A.2 Initiate action to Immediately restore spent fuel pool boron concentration to within limit.

t SU'RVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR '3.7.15.1 Verify the a it 'Juel pool boron concentration is within limit. (48 hour-s-7 g,g  ;

~

4.s  !

1 I

BYRON .-UNITS 1 & 2 3.7.15 - 1 Amendment

r Spent Fuel Assembly Storage 3.7.16 3.7 PLANT SYSTEMS 3.7.16 Spent Fuel Assembly Storage

-LC0 3.7.16 Each spent fuel assembly stored .in the spent fuel pool sha}: _

>03'*f a. Region 1 of $c'sef L OdC .Spe*,C [ueIpco{ doray feeh Have an initial nominal enrichment of s 4.7 weight

. percent U-235 or satisfy a minimum number of Integral Fuel Burnable Absorbers (IFBAs) for higher initial enrichments up to 5.0 weight percent U-235 to permit storage in any cell location.

V

b. Region 2 fc.se/A Oc<t.sj)entluelpool h Stof}s (sel'S Have a combination of initial enrichment, burnup. and decay time within the Acceptable Burnup Domain of Figure 3.7.16-1, 3.7.16-2, or 3.7.16-3, as applicable-

. for that storage configuration.

Y c.

f Interface Requirements for d~cre/L C a t .rg er: Uuc / oo/ storge cae6 Comply with the Interface Requirements within and between adjacent. racks.

4

)

APPLICABILITY: Whenever fuel assemblies are stored in the spent fuel pool.

Mr d.

R.pn / cl Mckee speast hel pool steige. ,selcs l N '

[lar a n is, tid no,,,iuf e nr,'c/,,,eist & &.r.o ue is pacenc u- zw to pu,.,.t serrye. nt cett ca t%.

Han a ocaa a th J inM c~ rad and bury \

lai ltlik k ticeef alvle.t ./)ury bo,y<h d Rya 20000 mi 7

HM

/) ///

.c / /if ~

Z nno ////

z _ovuu ffff T /Hi'

23

.nn,n uuuu

/#

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lNACCE? TABLE BURNU? DOMAIN nnn i i avuu -

--[ _

.w

-.C 2.0 3.0 4.0 5.0

N:T:AL l'-235 E N R:C H.T:ENT (w/c)

Figure 3.7.16-1 (page 1 of 1)

Region 2 All all R g emen_ts

( o a p o ,e J p a Fm /. b / . h y 4 ,e) l

%A 1 BYRON - UNITS 1 & 2 3.7.16-3 Amendment

q Spent Fuel Assembly Storage

.3.7.16

'5000' DECAY gnnnn.

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. . . . < . . . . v F1gure 3.7.16-2 (page 1 of 1) )

Reaion 2 3-out-of-4 Checkerboard Configuration Burnup Credit Requirements

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u BYRON' UNITS 1 & 2 3.7.16-4 Amendment

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4.0 4.2 . .: 4.6 4.8 5.0 INIT:A~ ~J-235 ENR:CHMENT (w/o;

. Figure 3,7.16-3 (page 1 of~1)

Region 2'2-out-of-4 Checkerboard Configuration'Burnupr i Credit Requirements

, (Sieph Cat Sped Fud Pcol 5ftrys Racks)

~

BYRON - UNITS 1 & 2 3.7.16-5 '

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N:T:A. 1-235 EN:';:C:O:ENT ' w/o ; '

4 Fi Region 2 '" ::"gure :c 3.7.lT-1

+ ;r:c ;r O (page nu; C1 ccit of 1)Requirements  ;

j Fuel Asymbh dunwp l (nottee speseFuJ PoolStume Raeb) l BYRON - UNITS 1 & 2 3.7.16$6i Amendmentk

q l

Design Features 1 4'. 0 l

LDESIGNFEATURES(continued) l 4 3 , Fuel Storage i4' 3.1 Criticality

, os applica6le, The spent fuel storage. racks are designed and shall be maintained with:

a. Fuel assemblies-havin a maximum'U-235 enrichment of 5.0 weight percent: aFec.& 4 0~ 0 s[-fuc/poof 4&r c' feen (
b. < 1.0 if fully flooded with unborated water whic (includes an allowance for uncertainties as descr

~WCAP-14416-NP-A, " Westinghouse Spent Fuel _ Rack Criticality j

-Analysis Methodology": '

f g yf g g,

c. s 0.95 if fully flooded with water orated to 50 ppm. <

wNich includes an allowance for uncertainties as described in.WCAP-14416-NP-A. " Westinghouse Spent Fuel-Rack Criticality Analysis Methodology": g

d. g,,;79p,g,c,f,,cfy,/j,,/3f,,,y,b>

nominal 10.32 inch north-south and 10.42 inch east-west "e f enter to center tance between fuel assemblies placed in Region 1 racks: v e ' Gseph Oat spent feel occ{Jfcia e Meh,

e. nominal 9.03 inch j)a(ssemblies centerin placed to center Region distance etween fuel 2 racks. 1 j

a 4.3.2 Drainaae

{

i The spent fuel pool is designed and shall be maintained to' prevent i inadvertent draining of the pool below elevation' 423 ft. 2 inches.

4.3.3 Caoacity The spent fuel pool is designed and shall e maintained with a storage capacity limited to no more than fuel assemblies.

.t99'l f

F].- 14tG speni wkk untse,'ateJ fueipcr/

water clu, keH ?o.'16 xerop(*fdeo whin ine an a ifthaanee SuG flo'M he anecli a s de<ctak d k Mc/tec Znterno Wa( Reycd //Z- 9f209'/, CnWeslih }

IlnaI su for ogron/8raiksel Rut tosdtrat>Whoj=d," ?!ojeee i do: yPo?'/'l; nee; g.

fce north.-flolfee sodi spe-t mi fueI a>/ s(My neb a nominsf /O 67'lh) i belwees fuel assen.flib placed kyh lm i Nets : a 'u!

k. Fee Heltec. w.r Suel ocol stor~r:- rach a nzmbul f.9'7 he L Qenter to ce 'reeye betwe% ruel esses.6tses faced <> 4'e im 3 raeb. i

. BYRON ~- UNITS 1 & 2 ^

4. 0 - f' ndment h J

Spent Fuel Pool Boron Concentration B 3.7'.15 B 3.7 PLANT SYSTEMS B 3.7.15 Spent Fuel Pool Boron Concentration BASES BACKGROUND The spent fuel pool provides for storage of various fosyk catsped Westinghouse Optimized Fuel Assembly (OFA) types of fue./f ul stortJc different initial fuel enrichments and exposure histories in two distinct regions. (For this discussion, the term 0FA is intended to refer to the specific reduced fuel rodlet diameter, and includes all analyzed fuel types with this diameter, such as Vantaoe 5.); There are 23 separate racks fdE6T d 3.7.6-/./ which provide placement locations for a total of 2870 new or used fuel assemblies. Included in this are six specific storage locations in one of the racks for placement of failed fuel assemblies. These locations are identified as (Aese, the failed fuel storage cells. Of % ef23 racks. four are designated " Region 1" with the remaining 19 racks designated as " Region 2" The analytical methodology used to develop the criticality analyses has been reviewed ana approved by the NR'C (Ref. 1)j 2dSW 6 3.%-l. A Sses oat soe-r Fud thi See Raeb Regibn 1 rac'ks contain 392 cells which are analyzed for storing Westinghouse OFAs in an "All Cells" arrangement (that is, the criticality analysis assumes that spent fuel assemblies reside in all available cell locations, with the exception of the boundary requirements). The stored fuel j assemblies may contain an initial nominal enrichment of '

s 4.7 weight percent U-235 (without Integral Fuel Burnable Absorbers (IFBAs) installed) up to an initial nominal enrichment of 5 5.0 weight percent U-235. provided that the requi,r nt for a minimum number of 16 IFBAs is met J (Refd The IFBAs are required to have, as a minimum, a boron i ding of 1.0X. equal to an amount of ,

1.5 mg B"/ inch. This is the minimum standard poison ]

material loading offered by Westinghouse for 17X17 0FAs. j Region 2 racks contain 2472 cells which are also analyzed )

for storing Westinghouse OFAs in a combination of storage l configurations These patterns are: l

1) "All Cells" Storage:  !
2) ~3--out-of-4 Checkerboard" Storage: and l
3) "2-out-of-4 Checkerboard" Storage.

BYRON - UNITS 1 & 2 B 3.7.15 - 1 Revision /

l

1 i

INSERT B 3.7.15-1.1 i

in addition, during the installation of Holtec spent fuel pool storage racks, both Holtec and Joseph Oat spent fuel pool racks will be in the spent fuel pool. At the completion of l installation, only Holtec spent fuel pool storage racks will be in the spent fuel pool.

INSERT B 3.7.15-1.2 The 23 Joseph Oat spent fuel pool storage racks will be replaced with 24 Holtec spent fuel pool storage racks, which provide placement locations for a total of 2984 new or used fuel assemblies. Of the 24 Holtec spent fuel pool storage racks, four are designated " Region 1" with the remaining 20 racks designated as " Region 2." The analytical methodology used for the criticality analyses is in accordance with established J NRC guidelines (Ref. 2).

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i Spent Fuel Pool Boron Concentration B 3.7.15 BASES BACKGROUND (continued)

For the "All Cells" storage configuration, the stored fuel assemblies may contain an initial nominal enrichment of s 1.14 weight percent U-235 (without taking credit for fuel

. burnup or radioactive decay of' fuel constituents) up to an initial' nominal enrichment of s 5.0 weight percent U-235 when fuel.burnup and radioactive decay of fuel constituents are credited.

For. the "3-out-of-4 Checkerboard" storage configuration, the stored fuel assemblies may contain an initial nominal enrichment of s 1.64 weight percent U-235 (without taking credit for fuel burnup or radioactive decay of fuel .

constituents) up to an initial nominal enrichment of s 5.0 weight percent U-235. when fuel burnup and radioactive decay of fuel constituents are credited. In this storage pattern, there can be no more than three' stored assemblies in any 2X2 matrix of cell lattices.

For the "2-out-of-4 Checkerboard" storage configuration. the stored fuel assemblies may contain an initial nominal enrichment of s 4.10 wei credit for fuel burnup) ght up percent U-235nominal to an initial (withoutenrichment taking of 5 5.0 weight percent U-235. when fuel burnup is credited.

In this storage pattern, no two fuel assemblies may be stored " face adjacent" (that is, there must be an empty cell opposite each face of the fuel assembly),

f M (/ F 6 3. 7./ f - 1 1 The water in the spent fuel pool normally contains soluble boron which results in large subcriticality margins under actual operating conditions.

BYRON-- UNITS 1 & 2 B 3. 7.15 - 2 Revision /

I

INSERT B 3.7.15-2.1 Holtec Soent Fuel Pool Storaae Racks Region 1 racks contain 396 cells which are analyzed for storing Westinghouse OFAs in an "All Cells" arrangement (that is, the criticality analysis assumes that spent fuel _'

assemblies reside in all available cell locations). The stored fuel assemblies may contain an initir' nominal enrichment of s 5.0 weight percent U-235 (with or without Integral Fuel Mmable Absorbers (IFBAs) installed) (Ref. 4).

' Region 2 racks contain 2588 cells which are also analyzed for storing Westinghouse OFAs in an "All Cells" arrangement (that is, the criticality analysis assumes that spent fuel assemblies reside in all available cell locations). For the "All Cells" storage

)

configuration, the stored fuel assemblies may contain an initial nominal enrichment of '

s 5.0 weight percent U-235 with credit for bumup.

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o I Spent Fuel Pool Boron Concentration B 3.7.15 BASES

. r

,rdsERT 8 3.'W4l}

APPLICABLE' NRC approved methodologies wer &

SAFETY ANALYSES criticalityanalysts,(Ref.Ik[eusedtodevelopthe Th fuel handling accident nalyses are provided in Reference The accident analyses for fle, fasep4 Oat' or critical,ity and spent fuel poo dilution are rovided 1 sfaatfuc/ f,o t Reference ' =d A respectively. Ao e (oe/

(foc semtAe roulony.esr se rat )

J##Jo raeb - - The critica y ana ses for the spent ue assemb y storage

. rack's confirm that k,,, remains < 1.0a(including de3 cc.6cl uncertainties E id toferances) at a 95% probability with a 95% confiden'ce level (95/95 basis), based on the accident condition of the pool being flooded with unborated water.

s for (4c 755efk &f5pt Thus, the design of both regions assumes the use of fuc( f#,( gfchJc nedre unborated water while maintaining stored fuel in a subcritical condition. .

Q ad 6 OM, for +lx Holfec-l fpent(ve/g,s/Jtstop However, the presence of soluble boron has been credited to I fo'g ' provide adequate safety margin to maintain spent fuel assembly storage rack k,y 5 0.95 (also on a 95/95 basis) for all postulated accident scenarios involvmg dropped or-misloaded fuel assembliesand loss of spent fuel pool )

(/tt bcd //o/te */ temperature control.. Crediting the presence of soluble  !

'T[scp4 04t spent 6dy/ Doron for mitigation of these scenarios is acceptable based 5(cte e rdefi) on applying the " double contingency principle" which states that there is no requirement to assume two unlikely, independent, concurrent event to en ure protection against  :

6 a criticality accident (Refs. 4,and's).

(fte t4c Josef Daf' '

I s0ent $ vel 0cc/ stooJc-The accident analyses address the fo lowing five postulated N 45 h ) scenarios: j

1) fuel assembly drop on top of rack: I
2) fuel assembly drop between rack modules; i
3) fuel assembly drop between rack modules and spent '

fuel pool wall:

4) change in spent fuel pool water '.amperature; and
5) fuel assembly loaded contrary to placement  :;

restrictions.

Of these, only the last two have the capacity to increase reactivity beyond the analyzed condition, f N W la t4e fcsepLbst spuf (velpoof atop e. y toeks,  ;

and e 40 ens &cs 2,3p !T hae &.cqc& l 12 lacrease rese(wit for W ff, Nee spear h et porsbry nelo. y 1

I BYRON - UNITS 1 & 2 B 3.7.15 - 3 Revision /

d

INSERT B 3.7.15-3.1 and methodologies in accordance with established NRC guidelines were used to develop the criticality analyses (Ref. 2) for the Holtec spent fuel pool storage racks I

Spent Fuel Pool Boron Concentration B 3.7.15 BASES I APPLICABLE SAFETY ANALYSES (continued) p g gg 4 A t p ,f .fy,/p s q ,, nets, Calculations were performed to determine the reactivity change caused by a change in spent fuel pool water temperature outside the normal range (50 - 160*F). For the change in spent fuel pool water temperature accident, a temperature range of 32 - 240*F is considered. In all cases. additional reactivity margin is available to the 0.95 k,,, limit to allow for temperature accidents. :The temperature change accident can occur at any time during l operation of the spent fuel pool.

+ -

fA / 5(4r 6 3.'7./f4 / For the fuel assembly misload accident. calculations were performed to show the largest reactivity increase caused by a Westinghouse 17X17 0FA fuel assembly misplaced into a storage cell for which the restrictions on location.

N fAIMRT b 3 7./f-4,

- enrichment, or burnup are not satisfieds The assembly g'fgg i misload accident can only occur during fuel handling operations in the spent fuel pool.

For the above postulated accident conditions, the double contingency principle can be applied. Specifically the presence of soluble boron in the spent fuel pool water can be assumed as a realistic initial condition since not assuming its presence would be a second unlikely event.

For the #4.r /v Og gpentfuelpoolsolubleboronhasbeencreditedinthe .

l

,/ Jfornoe, criticality safety analysis to offset storage rack and fuel t[ent fue/ v' assembly tolerances. calculational uncertainties.

Vacf'e 1

uncertainty associated with burnup credit and the reactivity

_ increase caused by postulated accident conditions.j i

( 7.

Based on the above discussio). should a s

~s Mater temperature change accident or a fuhent fuel pool l assembly misload

',2) ccident occur in the Region 1. Region 2. or failed fuel

.[or. the 785Y( Oit / storage cells, k,,, will be maintained s to 0.95 due to the '

Me fo#/Jhr^fS

~' 38 ~'

) presence of at least 550 ppm (no fuel handling) or 1650 ppm ~

(during fuel handling) of soluble boron in the spent fuel pool water.

~n, ZWSERT* 8 3. 7 ff4.tf-)

. / .s ,,/

1 i

i BYRON - UNITS 1 & 2 B 3.7.15 - 4 Revision /

_. ]

INSERT B 3.7.15-4.1 Calculations were also performed, for the Holtec spent fuel pool storage racks, for a spent fuel pool temperature of 4*C (39 F) which is well below the lowest normal operating temperature (50 F). Because the temperature coefficient of reactivity in the spent fuel pool is negative, temperatures greater than 4 C will result in a decrease in reactivity.

INSERT B 3.7.15-4.2 Calculations were also performed to show the largest reactivity increase caused by a Westinghouse 17X17 OFA fuel assembly misplaced into a Holtec Region 2 storage cell for which the restrictions on enrichment or burnup are not satisfied.

INSERT B 3.7.15-4.3 For the Holtec spent fuel pool storage racks, spent fuel pool soluble boron has been credited in the criticality safety analysis to offset the reactivity caused by postulated accident. conditions. Because the Region 1 racks are designed for the storage of fresh fuel assemblies, a fuel assembly misload accident has no consequences from a criticality standpoint (i.e., the acceptance criteria for storage are satisfied by all assemblies in the spent fuel pool).

INSERT B 3.7.15-4.4 For the Holtec spent fuel pool storage racks, should a fuel assembly mistoad accident occurin the Region 2 storage cells, keff will be maintained 5; 0.95 due to the presence of

)

at least 300 ppm of soluble boron in the spent fuel pool water.

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r Spent Fuel Pool Boron Concentration B 3.7l15 i BASES

. APPLICABLE SAFETY ANALYSES (continued)

/ spent fuel pool dilution analysi ef.

4. g g,Yf , g has been performed as required by Reference N.9 The analysis assumes spu.ffy,Ipoi an initial boron concentration of 2 0 ppm. The dilution  !

analysis concludes that an unplanned or inadvertent event '

J feradc ( ekt #

that would rest.lt in the dilution of the spent fuel pool boron concentration from 2000 ppm to 550 ppm (minimum non-accident boron concentration) is not credible.

(f,.~ ffc g,c[t, y, Interface recuirementsjhave been established to ensure km is maintainec within the appropriate limits. There are  ;

5 pent fuc/ ool f(c/oye interface requirements between Region 1 racks, between l A ,,, J Region 1 and oe gion 2 racks, between Region 2 racks. and .

within racks between different checkerboard configurations.

These requirements are necessary to account for unique geometries and configurations which exist at the interfaces.

Interface requirements exist between adjacent ' racks to account for the potential reactivity increase in 3-out-of-4 and 2-out-of-4 storage configurations along the interface with non-aligned racks.

The concentration of dissolved boron in the spent fuel pool 4 satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii). J LCO The spent fuel pool boron concentration is require o e

$,0dk

  • 2000 ppnk The specified concentration of dissolved boron f 2 3ccfAo (ce //,e //clece -

in the spent fuel pool preserves the assumptions used in the /

Jgod fuelgw/St c/U analyses of the potential critical accident scenarios as / .,

e,cks ud described in References 2. 3. cr.d 4. " i: concentraticr of dissc'"cd bcrcr is the minimum required concentration for fuel assembly storage and movement within the spent fuel fu flci %seph Cat Spust poo3, , ,

(uct gccf stcraje. ra eVs, ,

Ms disseIdef befo<

f oble a 6 app o'c fca' fin & cpl. Cals speut 6onentreh m ef 2cco ff m-fuelpool stcrye caeks INSCAT 6 3.7.lf-C.I BYRON'- UNITS 1 & 2' B 3.7.15 - 5 Revisionf/

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U:

l lNSERT B 3.7.15-5.1 The dissolved boron concentration of 300 ppm bounds the minimum required concentration for accidents occurring during fuel assembly movement within the spent l fuel pool for the Holtec spent fuel pool storage racks. During installation of the Holtec ,

l spent fuel pool storage racks, when both Joseph Oat and Holtec spent fuel pool storage  !

racks are in the spent fuel pool, the more restrictive of the two minimum boron concentration limits (i.e.,2000 ppm) is required to be met. After removal of all Joseph Oat spent fuel pool storage racks, only the 300 ppm boron concentration limit is required to be met.

l I

Spent Fuel Pool Boron Concentration B 3.7.15 BASES APPLICABILITY This LCO applies wh never fuel assemblies are stored in the spent fuel pool.

(Fu Jewp A Cat Jguf4c/ds,,fo rects ee/y)

The presence of soluble boron ( r,trati n:) is assumed in the criticality analyses and'is credited for

_ , ensuring that spent fuel pool k , will be maintained 5 0.95 accidedeco/s,tece aaJ t a 95% confidence level for aNestorage configurations.

The 2000 ppm minimum boron concentration is also an initial condition in the spent fuel pool dilution 'analysisr Therefore, the restriction on soluble boron concentration in the spent fuel pool water must be maintained at all times when fuel assemblies are stored in the spent fuel pool.

&o&1[se 4. T t spent fueIJ odabot* GekS V

ACTIONS The ACTIONS have been modified by a Note indicating thA LCO 3.0.3 does not apply.

A.1 and A.2 When the concentration of boron in the spent fuel pool is less than required, immediate action ruust be taken to ,

preclude the occurrence of an accident or to mitigate the '{

l consequences'of an accident in progress. This is most J efficiently achieved by immediately suspending the movement of fuel assemblies. This does not preclude movement of a fuel assembly to a safe position. Immediate actions are al_ take_ to restore spent fuel pool boron concentratio

- avuu ww .

If mov.ing fuel assemblies while in MODE 5 or 6. LCO 3.0.3 would not specify any action. If moving fuel assemblies while in MODES 1. 2. 3. and 4. the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of fuel assemblies is st sufficient reason to require a reactor shutdown.

BYRON - UNITS 1 & 2 B 3.7.15 - 6 Revision [

_ i

c oent Fuel Pool Boron Concentration B 3.7.'15 BASES

-SURVEILLANCE' SR 3 7.15.1 REQUIREMENTS This SR verifies that the concentration of boron in the spent fuel pool is within the required limit. As long as

,. this SR is met. the analyzed accidents are fully addressed.

f#SE8'f 5 3.7./f-71 Th 48 ho r freqdency ys apprdpriat based bope/ating e erie e and/tecause significant hanges in thd boro oncen ratio /in t spent uel p 1 are iffic lt to prod e wi ut d ctio consi ering e lar e volpme of wat cont ned' the s nt fu pool An alysighas co clude 'that a spent uel po61 boro dilu u ' vent of '

ffici t magpitude redugf boron /c uratior.' belo the inim non-arcident requirpment is/no.uc.a/dible/(Rei.

t cr 4).

REFERENCES 1. WCAP-14416-NP-A "W2stinghouse Spent Fuel Rack l Criticality Analysis Methodology " Rev.1. dated i November. 1996.

=

rdStnf N a 3.9.if-9.1, 3,2< CAC-97-162 " Byron and Braidwood Spent Fuel Rack Criticality Anab cis Using Soluble Boron Credit."

dated May. 1997.

f3: UFSAR. Section 15.7.4.

4A " Byron /Braidwood Spent Fuel Pool Dilution Analysis."  ;

Rev. 3. dated June 17. 1997. '

7A Double contingency principle of ANSI N16.1 - 1975, as l specified in the April 14, 1978 NRC letter 1 (Section 1.2) and implied in the proposed revision to  !

Regulatory Guide 1.13 (Section l'4. Appendix A).

fE ANSI /ANS 8.1 - 1983 "American National Standard for Nuclear Criticality Safety in Operations with Fissionable Materials Outside Reactors."

1.T. Safety Evaluation Report (SER) dated October 25. 1996, issued by the Office of Nuclear Reactor Regulation for Topical Report WCAP-14416-NP-A " Westinghouse Spent Fuel Rack Criticality Analysis Methodology."

BYRON - UNITS 1 &.2 B 3.7.15 - 7 Revision /

j

INSERT B 3.7.15 7.1 The 7 day frequency is appropriate based on operating experience and takes into consideration that no major replenishment of pool water is expected to occur over such a short period of time.

INSERT B 3.7.15-7.2

2. NRC Memorandum from L. Kopp to T. Collins, dated August 19,1998, " Guidance on the Regulatory Requirements for Criticality Analysis of Fuel Storage at Light Water Reactor Power Plants."

INSERT B 3.7.15-7.3

4. Holtec International Report, Hl-982094, " Criticality Analysis for the Byron /Braidwood Rack Installation Project," Project No. 80944,1998.

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t Spent Fuel Assembly Storage B 3.7.16 B 3.7 PLANT SYSTEMS B 3:7.16 Spent Fuel Assembly' Storage BASES fes< p Gatspe>C~

' BACKGROUND The spent fuel pool provides for storage of various Westinghouse Optimized Fuel Assembly (0FA) types of &c./I,,/ storJct different initial fuel. enrichments and exposure histories in two distinct regions. (For this discussion. the term 0FA is intended to refer to the specific reducea fuel rodlet diameter, and includes all analyzed fuel types with this' fgrggr g 3.7.6-/./

V diameter. such as Vantage 5.)j There are 23 separate racts which provide placement locations for a total of 2870 new or used fuel assemblies. Included in this are six specific j storage locations in one of the racks for placement of failed fuel assemblies. These locationsJre identified as fAese, the failed fuel storage cells. Of %ef23 racks. four are designated " Region 1" with the remaining 19 racks designated as " Region 2". The analytical methodology used to develop I

.the criticality analyses has been reviewed and approved by the NRC (Ref. 1)j I g t y 8 3 M - l. A ~ Gsuh w snes fuel Aoi Stor +o kka Reg 1bn 1 rac'ks contain 392 Cells which are analyzed for storing Westingnouse OFAs in an "All Cells' arrangement (that 15. the criticality analysis assumes that spent fuel assemblies reside in all available cell locations, with the exception of the boundary requirements). The stored fuel assemblies may contain an initial nominal enrichmant of s 4.7 weight percent U-235 (without Integral Fuel Burnable Absorbers (IFBAs) installed) up to an initial nominal enrichment of s 5.0 weight percent U-235. provided that the i requttement for a minimum number of 16 IFBAs is met (RefGO] . The IFBAs are required to have as a minimum, a i boron loading of 1.0X. equal to an amount of j 1.5 mg B"/ inch. This 15 the minimum standard poison j material loading offered by Westinghouse for 17X17 0FAs.

l l

Region 2 racks contain 2472 cells which are also analyzed for storing Westingnouse OFAs in a combination of storage configurations. Tnese patterns are.

1) "All Cells" Storage: '
2) "3-out-of-4 Cneckerboard" Storage: and
3) "2-out-of-4 Checkerboard" Storage.

. BYRON - UNITS 1 & 2 B 3.7.16 - 1 -

Revision [

1

t INSERT D 3.7.15-1.1 In addition, during the installation of Holtec spent fuel pool storage racks, both Holtec and Joseph Ost spent fuel pool racks will be in the spent fuel pool. At the completion of installation, only Holtec spent fuel pool storage racks will be in the spent fuel pool.

i INSERT B 3.7.15-1.2 I J

The 23 Joseph Ost spent fuel pool storage racks will be replaced with 24 Holtec spent fuel pool storage racks, which provide placement locations for a total of 2984 new or used fuel assemblies. Of the 24 Holtec spent fuel pool storage racks, four are designated " Region 1" with the remaining 20 racks designated as " Region 2." The j analytical rnethodology used for the criticality analyses is in accordance with established i NRC guidelines (Ref. 2).

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Spent' Fuel Assembly Storage B 3.):16

~ BASES IBACKGROUND(continued)

For the "All. Cells" storage configuration the stored fuel assemblies may contain an initial nominal enrichment of s l.14 weight percent U-235 (without taking credit for fuel burnup or radioactive decay of fuel constituents) up to an initial nominal enrichment of s 5.0 weight percent U-235.

when fuel burnup ar.d radioactive decay of fuel constituents are credited.

For. the "3-out-of-4 Checkerboard" storage configuration. .the stored fuel assemblies may contain an initial nominal enrichment of's 1.64 weight percent U-235 (without taking credit for fuel burnup or radioactive decay of fuel ,

constituents) up to an initial nominal enrichment of s 5.0 weight percent U-235, when fuel burnup and radioactive decay of fuel constituents are credited. In this storage pattern.

there can be no more than three stored assemblies in any 2X2 matrix of cell lattices.

For the "2-out-of-4 Checkerboard" storage configuration, the stored fuel assemblies may contain an initial nominal enrichment of s 4.10 wei credit for fuel burnup) ght up percent U-235 to an initial (without nominal taking enrichment of s 5.0 weight percent U-235. when fuel burnup is credited. -

In this storage pattern, no two fuel assemblies may be stored'" face adjacent" (that is there must be an empty cell i opposite each face of the fuel assembly).

rd5(AT d 3.7./5-21 The water in the spent fuel pool normally contains soluble boron which results in large subcriticality margins under actual operating conditions.

I BYRON - UNITS 1 & 2 B 3. 7.16 - 2 Revision [

I 4

INSERT B 3.7.15-2.1 Holtec Spent Fuel Pool Storace Racks Region 1 racks contain 396 cells which are analyzed for storing Westinghouse OFAs in an "All Cells" arrangement (that is, the criticality analysis assumes that spent fuel

)

j assemblies reside in all available celllocations). The stored fuel assemblies may contain an initial nominal enrichment of s 5.0 weight percent U-235 (with or without Integral Fuel Bumable Absorbers (IFBAs) installed) (Ref. 4).

Region 2 racks contain 2588 cells which are also analyzed for storing Westinghouse OFAs in an "All Cells" arrangement (that is, the criticality analysis assumes that spent fuel assemblies reside in all available cell locations). For the "All Cells" storage configuration, the stored fuel assemblies may contain an initial nominal enrichment of s 5.0 weight percent U-235 with credit for bumup.

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Spent Fuel Assembly Storage B 3.7.16 BASES

'siEW8~,.S3.I APPLICABLE NRC approved methodologies were SAFETY ANALYSES criticality analysest (Ref.1)* %d Th to ueldevelop handling the acclaent analyses areg"~'ided in Reference The accident analyses far (/,c, .7,3ejl Oa(- or criticality and spent fuel poo lution are orovided ,n Reference rd d respectively. (for tac. :ros.A o.c.reat Le/

sfext fuc/ f co t Jfsts e, raef5 stw e rad uty )

J .

The Critica y ana yses for the spen ue assembly storage rack's confirm that k,y remains < 1.0a(including e3cn uncertainties and tolerances) at a 95% probability with a 95% confidence level (95/95 basis), based on the accident condition of the pool being flooded with unborated water.

., for /4c I5efk O5ffpt Thus, the design of both regions assumes the use of unborated water while maintaining stored fuel in a factf#,I g,h)c e d e

ud 6 c.95, for fix Hollec subcritical condition.

gIent fue/O,c/Jtst7c However, the presence of soluble boron has been credited to f**D provide adequate safety margin to maintain spent fuel assembly storage rack k,y 5 0.95 (also on a 95/95 basis) for all postulated accident scenarios involving dropped or

(/cr 6,ft (,/tec.

/ .u/ misloaded fuel assemblie_s,.and loss of spent fuel pool emperature control.. Crediting the presence of soluble gyp 4 ont Jf eot 6dgoo/ Qoron for mitigation of these scenarios is acceptable based g,7, ,, 7,cr3 J on applying the " double contingency principle" which states that there is no requirement to assume two unlikely.

independent. concurrent evente to en ure protection against (ftet4cJosephO# a criticality accident (Refs. % and %),

' I sf ent (vet fccfstoroJc- The accident analyses address the fo lowing five postulated f'oh h ) scenarios:

1) fuel assembly drop on top of rack:
2) fuel assembly drop between rack modules:
3) fuel assembly drop between rack modules and spent fuel pool wall;
4) change in spent fuel pool water temperature; and
5) fuel assembly loaded contrary to placement restrictions.

Of these, only the last two have the capacity to increase reactivity beyond the analyzed condition jf W

Ic< Ntie fesp i br spe-.<t hcf poolaforsy. <<ek and og 4cen H n 2,.; p r h aa s . cap e,y n increau res e two y .

t kr w so m sp r Scr p/ se.<g c,ee., .

BYRON - UNITS 1 & 2 B 3. 7.16 - 3 RevisionjB'

INSERT B 3.7.15-3.1 and methodologies in accordance with established NRC guidelines were used to develop the criticality analyses (Ref. 2) for the Holtec spent fuel pool storage racks l

1 i

Spent Fuel Assembly Storage B 3.7.16 BASES APPLICABLE SAFETY ANALYSES (continued) Q Q M g y ,j .7)f s f y m e g .

D -s . / l- d..

Calculations were performed to determine the reactivity

~

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change caused by a change in spent fuel pool water l temperature outside the normal range (50 - 160*F). For tne '

change in spent fuel pool water temperature accicent a temperature range of 32 - 240'F is considered. In all cases. additional reactivity margin is available to Ine 0.95 ~ke , limit to allow for temperature accidents. Tne l temperature change accident can occur at any time during j operation of the spent fuel pool.

h

%WK4r' 6 3.'7./f-4./ For the fuel assembly misload accident. calculations were perforrrred to show the largest reactivity increase caused by a Westinghouse 17X17 0FA fuel assembly mispiated into a {

storage cell for which the restrictions on location,

- enrichment. or burnup are not satisfied s The assembiv ~

g,'f 4pg rWERT B 3 75-4.4 misload accident can only occur during fuel handling operations in the spent fuel pool.

For the above postulated accident conditions. the double contingency principle can be applied. Specifically. the presence of soluble boron in the spent fuel pool water can be assumed as a realistic initial condition since not {

C assuming its presence would be a second unlikely event.

  • For sh e 5.re.d. C y $ pent fuel pool soluble boron has been credited in the ftp:4fue/da,/J!ce),o criticality safety analysis to offset storage rack and fuel  ;

assembly tolerances calculational uncertainties. J Vd'jd uncertainty associated with burnup credit and the reactivity I increase caused by postulated accident conditions j IId5(6r 8 3 7 Based on the above discusslog. should a spent fuel pool l water temperature cnange accident or a fuel assembly misload I

< f y t/,e ygf (O,f g accident occur in the Region 1. Region 2. or failed fuel

, storage cells, k,.. will be maintained s to 0.95 due to the d,, #^f t r" presence of at least 550 ppm (no fuel handling) or 1650 ppm (during fuel handling) of soluble boron in the spent fuel pool water rHRT 8 3.7 tr-M 1

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. BYRON - UNITS 1 & 2 B 3.7.16 - 4 Revision [

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INSERT B 3.7.154.1 Calculations were also performed, for the Holtec spent fuel pool storage racks, for a spent fuel pool temperature of 4*C (39'F) which is well below the lowest normal operating temperature (50*F). Because the temperature coemeient of reactivity in the spent fuel pool is negative, temperatures greater than 4'C will result in a decrease in reactivity.

INSERT B 3.7.15-4.2 Calculations were also performed to show the largest reactivity increase caused by a Westinghouse 17X17 OFA fuel assembly misplaced into a Holtec Region 2 storage cell for which the restrictions on enrichment or bumup are not satisfied.

INSERT B 3.7.15-4.3 For the Holtec spent fuel pool storage racks, spent fuel pool soluble boron has been credited in the criticality safety analysis to offset the reactivity caused by postulated accident conditions. Because the Region 1 racks are designed for the storage of fresh fuel assemblies, a fuel assembly misload accident has no consequences from a criticality standpoint (i.e., the acceptance criteria for storage are satisfied by all assemblies in the spent fuel pool).

INSERT B 3.7.15-4.4 For the Holtec spent fuel pool storage racks, should a fuel assembly mistoad accident occur in the Region 2 storage cells, keff will be maintained s 0.95 due to the presence of at least 300 ppm of soluble boron in the spent fuel pool water.

i

Spent Fuel Assembly Storage ,

B 3.7.16 I BASES APPLICABLE SAFETY' ANALYSES (continued)

/spentfuelpooldilutionanalysi ef. has been

) b'# h 8'[ l performed as required by Reference N 9 The analysis assumes {

sp-f 6a poo an initial baron concentration-of 20 0 ppm. Tne cilun on '

analysis concludes that an unplanned or inadvertent ever.t Jferade'rekt> that would result in the dilution of the spent fuel cool boron concentration from 2000 ppm to 550 ppm (minimum non-accident boron concentration) is not credible.

-(feffiyf', cat,gy,- Interface recuirements;have been established to ensure kg i is maintainec witnin the appropriate limits. There are spent fuel co( ((c/of interface requirements between Region 1 racks. between pg ,,, J Region 1 and Region 2 racks, between Region 2 racks. and within racks between different checkerboard configurations.

These reouirements are necessary to account for unique geometries and configurations which exist at the interfaces.

Interface requirements exist between adjacent racks to account for the potential reactivity increase in 3-out-of-4 4

)

and 2-out-of-4 storage configurations along the interface l with non-aligned racks. l I

The concentration of dissolved boron in the spent fuel pool (

satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

{

LCO The restrictions on the placement of fuel assemblies within j the spent fuel pool in accordance with the requirements in Er /6 JJM # Jpenf - the accompanying LCO ensure that the k (Aufpoc/ste.gcracks,a,$d pool will always remain < 1.0 assuming,y the of theisspent pool fuel flooded 6 c, er c w,n,- rye fo,/ with unborated water and s 0.95 assuming the presence of is i c,,, W, 4,utal 550 ppm soluble boron in the pooJ.

F '

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fAc H ,//ec g en f /nLC0 Figures 3.7.16-1and3.7.16-2.theAcceptableBurnup I

3, Pt/ d,fue, V reeks

. Domain lies on. above and to the left of the decay time line applicable to the fuel assembly to be stored. The e decay time for that assembly is measured from the time since fer ths Mcf 6d 5f",r the assembly was last discharged.

Ja/ pool s(cge /et/4 /nLC0F1gure3.7.16-3.theAcceptableBurnupDomainandthe Unacceptacle Burnup Domain are separated by a single line

-N because decay time is not credited in the 2-out-of-A (For fl.c 'Tiscpl, lof ye,sf Checkerboard storage configuration. The Acceptable Burnup

, g, Domain lies on. above. and to the left of the line.

1

. BYRON - UNITS 1 & 2 B 3. 7.16 - 5 Revision [ {

o...

p Spent Fuel Assembly Storage B 3.7 16 BASES LC0 (continued)

In each. figure. the use of linear interpolation between minimum burnups is acceptable.

APPLICABILlTY- This LCO applies whenever fuel assemblies are stored in the spent fuel pool.

ACTIONS The ACTIONS have been modified by a Note indicating that LCO 3.0.3 does not apply.

Fer th Ihlhe 9e tlud U ped ,rtog raeb, ir Leo gure, 3.'7.4 - e/, f/.c When the confi uration of fuel assemblies stored in the spent fuel poo is not in accordance with the requirements deceg&4/u dur'ug3c'*",'i of the LCO. immediate action must be taken to make the f//efa<dogand/cflu necessary fuel, assembly movement (s) to bring the configuration into compliance.

' lek cf .ibu burwp t/ufus eur,,c/+ rent g."u. If moving fuel assemblies while in MODE 5 or 6. LC0 3.0.3 would not specify any action. If moving fuel assemblies while in MODES 1. 2. 3. and 4. the fuel movement is independent of reactor operations. Therefore, inability to suspend movement of fuel assemblies is not sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.7.16.1 /

-REQUIREMENTS e " 5 agr ,g o, {

vm~m -SR 3.7.16.1,is performed $rior to storing the fuel assemb y cfwEar d 3.1/4 w/t in the intended spent fuel pool storage location. The {

us .m> frequency is appropriate because compliance with the SR j j

ensures that the relationship between the fuel assembly and j its storage location will' meet the requirements of the LC0 1 and preserve the assumptions of the analyses.

f This SR verifies by administrative means that the initial nominal enrichment of the fuel assembi or a minimum number I of 16 IFBAs is met to ensure that the ssumptions of the

~ g safety analyses are preserved, e

('b'H#Nl""J3Y'bO'

,(,5c,fcEp

\ &;

> ha ps s ccy c3 l

BYRON - UNITS 1 & 2 B 3.7.16 - 6 Revision

)

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l lNSERT B 3.7.16-6.1 SR 3.7.16.1 has been modified by a Note indicating that item a is only applicable for storage of fuel assemblies in Region 1 Holtec spent fuel pool storage racks, and item b l is only applicable for storage of fuel assemblies in Region 1 Joseph Oat spent fut' pool storage racks.

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Spent Fuel Assembly Storage B 3.7.16 l

{

BASES

. SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.16.2 I pgg g 3'7,g 7' f SR 3.7.16.2 is performed prior to storing the fuel assembly in the intended spent fuel pool storage location. The (

frequency is appropriate because compliance with the SR -j ensu.res that the relationship between the fuel assembly and l its storage location will meet the requirements of the LCO and preserve the assumptions.of the analyses.

a.s s llcolk.,

This SR: verifies by administrative means that th combination of initial enrichment. burnup, and decay timerof 1 the fuel assembly.is withi the Acceptable Burnup Domain of Figure 3.7.16-1, 3.7.16-2. 3.7.16-3qfor the intended storage configuration to ensure that the assumptions of the -)

safety analyses are preserved.

, or 3.'7. It --y SR 3.7.16.3 mm IId55FT d 3 7.h-7. R) SR 3.7.16.3 is performed prior to storing the fuel assembly )

7". in the intended spent fuel pool storage location. The I frequency is appropriate because. compliance ~with the SR ensures that .the relationship between the fuel assembly and its storage location will meet the requirements of the LCO and preserve the assumptions of the analyses.

\ This SR verifies by administrative means that the interface requirements (Ref. 2) within and between adjacent racks are met to ensure that the assumptions of the safety analyses are preserved.

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i BYRON - UNITS 1 & 2 B 3.7.16 - 7 Revision [

a l

m INSERT B 3.7.16 7.1 SR 3.7.16.2 has been modified by a Note indicating that Figures 3.7.16-1,3.7.16-2, and

-3.7.16 3 are only applicable for storage of fuel assemblies in Region 2 Joseph Oat spent fuel pool storage racks, and Figure 3.7.16-4 is only applicable for storage of fuel assemblies in Region 2 Holtec spent fuel pool storage racks.

INSERT B 3.7.16-7.2 SR 3.7.16.3 has been modified by a Note indicating that this SR is only applicable for storage of fuel assemblies in Joseph Oat spent fuel pool storage racks.

Spent Fuel Assembly Storage B 3.7.16 BASES I l

REFERENCES 1. WCAP-14416-NP-A " Westinghouse Spent Fuel Rack Criticality Analysis Methodology." Rev.1. dated November. 1996.

TASQ3f 8 3.1.l'E-9. 2 ^ =

3.7 CAC-97-162 " Byron and Braidwood Spent Fuel Rack Criticality Analysis Using Soluble Boron Credit."

y450f T 6 3.7./f- 7.J dated May. 1997.

.C. 8: UFSAR. Section 15.7.4.

4A " Byron /Braidwood Spent Fuel Pool Dilution Analysis." ,

Rev. 3. dated June 17. 1997.

7E Double contingency principle of ANSI N16.1 - 1975. as f specified in the April 14. 1978 NRC letter (Section 1.2) and implied in the proposed revision to l Regulatory Guide 1.13 (Section 1.4. Appendix A).

fX ANSI /ANS 8.1 - 1983 "American National Standard for I Nuclear Criticality Safety in Operations with  !

Fissionable Materials Outside Reactors." '

'l J'. Safety Evaluation Report (SER) dated October 25. 1996.

issued by tne Office of Nuclear Reactor Regulation for 3 j

Topical Report WCAP-14416-NP-A " Westinghouse Spent '

Fuel Rack Criticality Analysis Methodology."

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1 BYRON - UNITS 1 & 2 B 3. 7.16 - 8 Revision [

l

INSERT B 3.7.15-7.2

2. NRC Memorandum from L, Kopp to T. Collins, dated August 19,1998, " Guidance on the Regulatory Requirements for Criticality Analysis of Fuel Storage at Light Water Reactor Power Plants."

INSERT B 3.7.15-7.3

4. Holtec international Report, Hi 982094, " Criticality Analysis for the Byron /Braidwood Rack Installation Project," Project No. 80944,1998.

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ATTACHMENT B-3 INCORPORATED PROPOSED CHANGES TYPED PAGES BRAIDWOOD STATION REVISED PAGES 3.7.15-1 3.7.16-1 3.7.16-2 3.7.16 - 3 3.7.16-4 3.7.16- 5 3.7.16 -6 3.7.16 - 7 4.0 - 2 4.0 - 3 PfVISED BASES PAGES B 3.7.15-1 through B 3.7.15-10 B 3.7.16-1 through B 3.7.16-10 '

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-Spent Fuel Pool- Boron Concentration 3.7.15 3;7--PLANT SYSTEMS 3.7.15- Spent Fuel Pool Boron Concentration

_ r

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LC0. 3.7.15 - The spent fuel, pool. boron concentration shall be, as' applicable:

a. ~= 300 ppm for Holtec spent fuel pool storage racks: and

.. b . 2 2000 ppm for Joseph Oat spent fuel pool storage racks.

APPLICABILITY: Whenever fuel-assemblies'are stored in the spent fuel pool.

ACTIONS NOTE- - --

LCO 3.0.3 is not applicable.

CONDITION .RE'0VIRED ACTION ~ l COMPLETION TIME '

'A. ' Spent fuel pool boron A.1 Suspend movement of Immediately concentration not fuel assemblies in within limit. the spent fuel pool.

AND A.2. Initiate action to Immediately restore spent fuel pooT boron concentration to within limit.

. SURVEILLANCE-REQUIREMENTS SURVEILLANCE FREQUENCY

?SR. 3.7:15.1 _ Verify the' spent fuel pool boron 7 days  !

concentration is within limit.

'q.

BRAIDWOOD'-' UNITS 1 &-2-- 3.7.15 - 1 Amendment l

I Spent Fuel Assembly Storage 5 3.7.16

.3.7- PLANT' SYSTEMS-3.7.16_. Spent-Fuel Assembly _ Storage-1LC0 3.7.16 Each s shall, pent fuel assembly stored-in the spent fuel pool as applicable: ,

-'a . Region 1 of Joseph Oat-spent' fuel pool storage racks

' ave H an initial nominal enrichment of s 4.7 weight percent U-235 or satisfy-a minimum number of Integral Fuel' Burnable Absorbers (IFBAs) for higher _ initial enrichments'up to 5.0 weight percent U-235 to permit' storage in any cell location.

b. Region 2 of Joseph Oat ' spent fuel pool ~ storage racks .

Have'a combination of initial enri~chment. burnup, and decay time within the Acceptable Burnup Domain of ,

Figure 3.7.16-1, 3.7.16-2. or 3.7.16-3. as applicable '

for that storage configuration,

c. Interface Requirements for Joseph 0at spent fuel pool storage _ racks Comply with the Interface Requirements within' and between adjacent racks.
d. _ Region 1 of Holtec spent fuel pool storage racks Have an initial nominal enrichment of s 5.0 weight percent U-235 to permit storage in any cell location.
e. Region 2 of the Holtec spent fuel pool storage racks Have a combination of initial enrichment and burnup within the Acceptable Burnup Domain of Figure 3.7.16-4

'APPLICABILITYi Whenever fuel assemblies are stored in the spent fuel pool.

BRAIDWOOD - UNITS 1 & 2 3.7.16 - 1 Amendment 9

^P

T'

__k s Spent Fuel. Assembly Storage 3,7.16

~ ACTIONS NOTE- - -

LCO 3.'0.3 is not applicable.

' CONDITION REQUIRED ACTION. COMPLETION TIME A'. Requirements of .the - A.1 Initiate' action to Immediately LC0 not met. move the noncomplying fuel assembly into a location which restores compliance.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.16.1 ----NOTE Item a is only applicable for storage of fuel assemblies in Region 1 Holtec spent fuel pool. storage racks. Item b is only applicable for storage of fuel assemblies in Region 1 Joseph Oat-spent fuel pool storage' racks.

Verify by administrative means the Prior to c following requirements are met: -storing the fuel assembly

a. Initial nominal enrichment of the in Region 1
fuel assembly _is.5 5.0 weight percent U-235.

AND b .' Initial nominal enrichment of the

-fuel assembly is s 4.7 weight percent

.U-235 with less than the minimum number of-IFBAs or s 5.0 weight percent U-235 with the minimum number

-of IFBAs.

(continued)

BRAIDWOOD -' UNITS 1 & 2 3.7.16 - 2 Amendment

r;n ,

Spent Fuel. Assembly Storage 3.7.16

SURVEILLANCE REQUIREMENTS '(continued)

. SURVEILLANCE FRE0VENCY-SR 3.7.16.2- .- -

NOTE Figures 3.7.16-1 3.7.16-2, and 3.7.16-3 are only applicable.for storage of-fuel assemblies _in Region 2 Joseph Oat spent

' fuel pool storage racks. Figure 3.7.16-4 is only: applicable for storage of. fuel

. assemblies in Region 2 Holtec spent fuel pool storage racks ~ .

Verify by administrative means,the Prior to combination of initial enrichment, burnup, storing the and decay time, as a]plicable, of the fuel fuel assembly l, assembly-is within.tle Acceptable Burnup in Region 2 Domain of Figure 3.1.16-1, 3.7.16-2. I 3.7.16-3. or 3.7.16-4.

SR 3.7.16.3 -

NOTE -

Only applicable for storage of fuel assemblies in' Joseph Oat spent fuel pool storage racks.

Verify by administrative means the Prior to

. interface requirements within and between storing the adjacent racks are met. fuel assembly in the spent fuel pool -

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BRAIDWOODL-UNITS-1&2' 3.-7.16 - 3 Amendment l 1

L.

F Spent Fuel Assembly Storage 3,7:16 s

60000 DECAY TIME:

55030 ,

, 0 YEARS

/

I

/ ! > 5 YEARS

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50000 t I . i I

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1.0: 2.0. 3.0 4,0 5.0 INITIAL U-235 ENRICHMENT (w/o)

Figure 3.7.16-1 (page 1 of 1)

Region 2 All Cell Configuration Burnup Credit Requirements (Joseph Oat Spent Fuel Pool Storage Racks)

BRAIDWOOD - UNITS 1 & 2 3.7.16 - 4 Amendment

r

{:- Spent Fuel Assembly Storage 3.7.16 45000' , , ,

DECAY 40000 TIME:

l, 0 YEARS i' 5 YEARS

~

E 35000 i

/i/ 10 YEARS H I  ! I i 1 ! A A/ 15 YEARS 2 ACCEPTABLE / VIA 20 EARS

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1.0 2.0 3.0 4.0 5.0 INITIAL U-235 ENRICHMENT (w/o)

Figur e 3.7.16-2 (page 1 of 1)

Region 2 3-out-of-4 Checkerboard Configuration Burnup Credit Requirements (Joseph Oat Spent Fuel Pool Storage Racks)

BRAIDWOOD - UNITS 1 & 2 3.7.16 - 5 Amendment

Spent Fuel Assembly Storage 3.7cl6 5000 l l lll 1I I /

I /

4000 I I I / I E ACCEPTABLE /l L- BURNUP DOMAIN ' /  :

$ / I 3000 ,

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Figure 3.7.16-3 (page 1 of 1)

Region 2 2-out-of-4 Checkerboard Configuration Burnup Credit Requirements (Joseph Dat Spent Fuel Pool Storage. Racks)

BRAIDWOOD - UNITS 1 & 2 3.7.16 - 6 Amendment l v

r Spent Fuel Assemcly Storage 3.7:16 45000 , i i , ,

) i i i j i

.i!

i

40000 lL V,

ft l l t fa ii h35000 , l,i i l l /'ll

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i i iii >i 0 i 2 2.5 3 3.5 4 4.a o I INITIAL U-235 ENRICHMENT (w/o) i Figure 3.7.16-4 (page 1 of 1)

Region 2 Fuel Assembly Burnup Requirements (Holtec Spent Fuel Pool Storage Racks)

BRAIDWOOD - UNITS 1 & 2 3.7.16 - 7 Amendment i

y Design Features 4.0 DESIGN FEATURES (continued) -

4.3 Fuel Storage 4.3.1 Criticality The spent fuel storage racks are designed and shall be i maintained as applicable, with: I

a. Fuel assemblies having a maximum U-235 enrichment of 5.0 weight percent;
b. For Joseph Oat spent fuel pool storage racks. k , < 1.0 l if fully flooded with unborated water which includes an allowance for uncertainties as described in WCAP-14416-NP-A. " Westinghouse Spent Fuel Rack Criticality Analysis Methodology":
c. For Joseph Oat spent fuel pool storage racks. k rr s 0.95 if fully flooded with water borated to 550 ppm ewhich includes an allowance for uncertainties as described in WCAP-14416-NP-A. " Westinghouse Spent Fuel Rack Criticality Analysis Methodology";
d. For Joseph Dat spent fuel pool storage racks, a nominal 10.32 inch north-south and 10.42 inch east-west center to center distance between fuel assemblies placed in Region 1 racks:
e. For Jose)h Oat spent fuel pool storage racks, a nominal l 9.03 inca center to center distance between fuel assemblies placed in Region 2 racks.
f. s 0.95 if For fully Holtec floodedspent fuel pool storage with unborated racks.

water which inck,,iudes an allowance for uncertainties as described in Holtec International Report. HI-982094 " Criticality Analysis for Byron /Braidwood Rack Installation Project." Project No. 80944, 1998:

g. For Holtec spent fuel pool storage racks, a nominal 10.574 inch north-south and 10.888 inch east-west center to center distance between fuel assemblies placed in Region 1 racks: and
h. For Holtec spent fuel pool storage racks a nominal 8.97 inch center to center distance between fuel assemblies placed in. Region 2 racks.

l (continued) J l

BRAIDWOOD - UNITS 1 & 2 4. 0 - 2 Amendment l

Design Featu.res 4.0 DESIGN FEATURES-(continued) 4.3.2 Drainaae The spent fuel pool.is designed and shall be maintained to prevent inadvertent draining of the pool below.

elevation 423 ft 2 inches.

4.3.3 Canacity The spent fuel pool is designed and shall be maintained with a storage capacity limited to no more than 2984 fuel assemblies.

BRAIDWOOD - UNITS 1 & 2 4. 0 - 3 Amendment

m Spent Fuel Pool Boron Concentration B 3.7.15 B 3.7 PLANT SYSTEMS B 3.7.15 Spent Fuel Pool Boron Concentration BASES BACKGROUND The spent fuel pool provides for storage of various Westinghouse Optimized Fuel Assembly (OFA) types of different initial fuel enrichments and exposure histories in two distinct regions. (For this discussion. the term 0FA is intended to refer to the specific reduced fuel rodlet diameter, and includes-all analyzed fuel types with this diameter, such as Vantage 5.) In addition, during the installation of .

Holtec spent fuel pool storage racks, both Holtec and  :

Joseph Oat spent fuel pool racks will be in the spent fuel pool. At the completion of installation, only Holtec spent fuel pool storage racks will be in the spent fuel pool. There are 23 separate Joseph Oat spent fuel pool storage racks which provide placement locations for a total of 2870 new or used fuel assemblies. Included in this are six specific storage locations in one of the racks for placement of failed fuel assemblies. These locations are identified as  !

the failed fuel storage cells. Of these 23 racks. l l four are designated " Region i" with the remaining 19 '

racks designated as " Region 2". The analytical methodology used to develop the criticality analyses i has been reviewed and approved by the NRC (Ref. 1). '

The 23 Joseph Oat spent fuel pool storage racks will  !

be replaced with 24 Holtec spent fuel pool storage l racks, which provide placement locations for a total of 2984 new or used fuel assemblies. Of the 24 Holtec spent fuel pool storage racks four are designated "o.egion 1" with the remaining 20 racks designated as

egion 2." The analytical methodology used for the

! criticality analyses is in accordance with established i NRC guidelines (Ref. 2).

l Joseoh Oat Soent Fuel Pool Storace Racks Region 1 racks contain 392 cells which are analyzed for storing Westinghouse 0FAs in an "All Cells" arrangement (that is, the criticality analysis assumes that spent fuel assemblies reside in all available cell locations, with the exception of the boundary requirements). The stored fuel assemblies may contain an initial nominal enrichment of s 4.7 weight percent U-235 (without integral Fuel Burnable Absorbers BRAIDWOOD - UNITS 1 & 2 B 3.7.15 - 1 Revision

F Spent' Fuel' Pool Boron Concentration B-3.7.15

- BASES BACKGROUND (continued)

(IFBAs) installed) up.to an initial nominal enrichment. )

of.s 5.0 weight percent U-235 provided that the i

' requirement for a minimum. number of 16 IFBAs is met

-(Ref. 3). The IFBAs are required to have. as a

-l minimum, a boron loading of 1.0X.. equal to an amount of 1.5 mg B / inch. This is the minimum standard 8

- poison' material loading offered by Westinghouse _ for -

17X17 0FAs. ~;

Region 2-racks contain 2472 cells which are also analyzed for storing' Westinghouse OFAs in a combination of. storage configurations. These patterns are:

1) "All Cells" Storage: . ,

j

2) "3-out-of-4 Checkerboard" Storage; and e
3) "2-out-of-4 Checkerboard" Storage.

For the "All Cells" storage configuration, the stored fuel assemblies may contain an initial nominal enrichment of s 1 14 weight percent U-235 (without taking credit for fuel burnup or radioactive decay of fuel constituents) up to an initial nominal enrichment of s 5.0 weight percent U-235, when fuel burnup and radioactive decay of fuel constituents are credited.

For the "3-out-of-4 Checkerboard" storage configuration, the stored fuel assemblies may contain an initial nominal enrichment of s 1.64 weight percent U-235:(without taking credit for fuel burnup or radioactive decay of fuel constituents) up to an initial nominal enrichment of's 5.0 weight percent U-235, when fuel burnup and radioactive decay of fuel l

constituents are credited. In this storage pattern.  ;

there can be no more than three stored assemblies in l any 2X2 matrix of cell lattices. '

For the "2-out-of-4 Checkerboard" storage configuration the stored fuel assemblies may contain .

an initial nominal enrichment of s 4.10 weight percent

~

I U-235 (without taking credit for fuel burnup) up to an initial nominal' enrichment of s 5.0 weight percent  ;

~U-235. when fuel burnup is credited. In this storage pattern. no two fuel assemblies may be stored " face adjacent" (that is, there must be an empty cell opposite each face of the fuel assembly).

BRAIDWOOD - UNITS.1 & 2 B 3.7.15 - 2 Revision l

4, Spent Fuel Pool Bcron Concentration B 3.7.15 BASES:

l ~ BACKGROUND (continued)-

Holtec Soent Fuel Pool Storace' Racks Region 1 racks contain 396 cells which are analyzed for storing Westinghouse 0FAs in an "All Cells"

-arrangement (that is, the criticality analysis assumes

.that spent fuel assemblies reside in all available cell locations).- The stored fuel assemblies may

' contain an initial nominal enrichment of s 5.0 weight percent U-235 (with or without Integral Fuel Burnable Absorbers (IFBAs) installed) (Ref, 4).

Region 2 racks contain 2588 cells which are also analyzed for storing Westinghouse 0FAs in an "All Cells" arrangement (that is, the criticality analysis assumes that spent. fuel assemblies reside in all t

available cell locations). For the "All Cells" storage configuration, the stored fuel assemblies may contain an initial nominal enrichment of s 5.0 weicht p percent U-235 with credit for burnup.

I The water in the s)ent fuel pool normally contains l soluble boron whic1 results in large subcriticality margins under actual operating conditions.

i

. APPLICABLE NRC approved methodologies were used to develop SAFETY ANALYSES the criticality analyses for the Joseph Dat spent fuel pool storage racks (Ref. 1) and methodologies in accordance with established NRC guidelines were used to develop the criticality analyses (Ref. 2) for the Holtec spent fuel pool storage racks. The fuel handling accident analyses are described in Reference 5. The accident analyses for criticality i and spent fuel pool dilution (for the Joseph Oat spent i fuel storage racks only) are provided in References 3. .

4. and 6. respect'ively. .l The criticality analyses for the spent fuel assembly storage racks confirm that k remains < 1.0 for the JosephDatspentfuelpoolsluorage racks, and s 0.95, for the Holtec spent fuel pool storage racks (including uncertainties and tolerances) at a 95%

3robability with a 95% confidence level (95/95 basis).

Jased on the accident condition of the pool being BRAIDWOOD - UNITS 1 & 2 B 3.7.15 - 3 Revision l

m

. Spent Fuel Pool. Boron Concentration B 3.7.15-BASES

' APPLICABLE SAFETY ANALYSES (continued) flooded with.unborated water. Thus. the design of both regions assumes the use of unborated water while

.. maintaining stored fuel in a subcritical condition.

However. .the presence of soluble boron has been credited to provide adequate safety margin to maintain

. spent fuel assembly storage rack km s 0.95 (also on a.

95/95 basis) for all postulated accident scenarios involving dropped or misloaded fuel assemblies '(for both Holtec and Joseph Oat spent fuel pool storage racks) and loss of spent fuel pool temperature control (for the Joseph-Oat-spent fuel pool storage racks only). Crediting the presence of soluble boron for mitigation of these scenarios is acceptable based on applying the'" double contingency' principle" which states .that ~there is no requirement to assume two unlikely, independent. concurrent events to ensure protection against a criticality accident (Refs. 7 and 8). j l

The accident analyses address the following five.

postulated scenarios:

1) fuel assembly drop on top of rack: i
2) fuel assembly drop between rack modules:
3) fuel assembly drop between rack modules and i s]ent fuel pool wall-; -
4) clange in spent fuel pool water temperature; and
5) fuel assembly loaded contrary to placement restrictions.

Of these, only the last two have the c scity to increase reactivity beyond the analya condition, for the Joseph Oat spent fuel pool storage racks, and only scenarios 2. 3, and 5 have the capacity to increase reactivity for the Holtec spent fuel pool storage

, racks.

l- Calculations were performed, for the Joseph Oat spent i

fuel pool storage racks, to determine the reactivity change caused by a change in spent fuel pool water temperature outside'the normal range (50 - 160 F).

For the change in spent fuel pool water temperature accident..a temperature range of 32 - 240 F is considered. In all cases, additional reactivity

(

L BRAIDWOOD - UNITS 1 & 2 8 3.7.15 - 4 Revision  !

l 4

[

cu ,

Spent Fuel Pool Boron Concentration I B 3.7.15 {

BASES I

APPLICABLE SAFETY ANALYSES (continued) j margin is available to the 0.95 k,,, limit to allow for temperature accidents. The teinperature change accident can occur at any time during operation of the j spent fuel pool.

Calculations were also performed, for the Holtec spent I fuel pool storage racks. for a spent fuel pool j temperature of 4 C (39 F) which is well below the 1 lowest normal operating temperature (50 F). Because '

the temperature coefficient of reactivity in the spent fuel pool is negative temperatures greater than 4 C will result in a decrease in reactivity. )

i For the fuel assembly misload accident, calculations  !

were performed to show the largest vity reactivity  !

increase caused by a Westinghouse 17X17 0FA fuel i assembly misplaced into a Joseph Oat storage cell for  ! 1 which the restrictions on location, enrichment, or burnup are not satisfied. Calculations were also performed to show the largest reactivity increase .

caused by a Westinghouse 17X17 0FA fuel assembly I misplaced into a Holtec Region 2 storage cell for l which the restrictions on enrichment or burnup are not i satisfied. The assembly misload accident can only '

occur during fuel handling operations in the spent fuel pool.

For the above postulated accident conditions, the double contingency principle can be ap311ed.

Specifically, the presence of soluble )oron in the spent fuel pool water can be assumed as a realistic i

initial condition since not assuming its presence . l would be a second unlikely event. For the Joseph Dat i I

spent fuel pool storage racks. spent fuel pool soluble l l boron has been credited in the criticality safety {

analysis to offset storage rack and fuel assembly i tolerances. calculational uncertainties, uncertainty {

associated with burnup credit and the reactivity )

increase caused by postulated accident conditions. l For the Holtec spent fuel pool storage racks, spent fuel pool soluble boron has been credited in the criticality safety analysis to offset the reactivity caused by postulated accident conditions. Because the l Region 1 racks are designed for the storage of fresh I fuel a'semblies, s a fuel assembly misload accident has I no consequences from a criticality standpoint (i.e. . '

BRAIDWOOD - UNITS 1 & 2 B 3.7.15 - 5 Revision l

)

V, Spent- Fuel Pool Boron Concentrat. ion B 3.7.15 i BASES:

1

-APPLICABLE-SAFETY ANALYSES 1(continued)-

-- the acceptance criteria for storage are satisfied by  !

all-assemblies in the spent fuel' pool). 1 Based on the above discussion for the Joseph Oat spent  !

- fuel. pool storage racks, should a spent fuel pool.

water temperature change accident or a fuel assembly- H misload accident occur in:the Region 1, Region 2 or failed fuel storage cells, krr will be maintained  !

s 0.95 due to the presence o,f at least 550 ppm (no fuel handling) or 1650 ppm (during fuel handling) of soluble boron in the spent fuel = pool water. For the Holtec spent fuel pool storage racks, should a fuel .

. assembly misload accident occur in the Region 2 storage cells. k,,, will. be maintained s 0. 95 due to 4

the presence of at least 300 ppm of soluble boron in i the spent fuel pool water.

For.the Joseph Oat spent fuel pool storage racks, a spent fuel pool dilution analysis (Ref. 6) has been performed'as required by Reference 9. The analysis'  !

assumes an initial boron concentration-of 2000 ppm.

The dilution analysis concludes that an unplanned or inadvertent event.that would result in the dilution of

+he spent fuel pool boron concentration from 2000 ppm co;550' ppm (minimum non-accident boron concentration) is not credible.

Interface requirements (for the Joseph Oat spent fuel pool storage racks only) have been established to -

ensure k,,, is maintained within the appropriate limits. There are interface requirements between Region 1 racks. between Region 1 and Region 2 racks. l

. between Region 2 racks, and within racks between different checkerboard configurations. These requirements are necessary to account for unique '

geometries and configurations which exist at toe  ;

interfaces. Interface requirements exist between ,

adjacent racks to account for the potential reactivity l increase in 3-out-of-4 and 2-out-of-4 storage '

configurations along the interface with non-aligned racks j The concentration of dissolved boron in the spent fuel pool satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii). '

l l'

LBRAIDWOOD UNITS 1~& 2 B 3.7.15 - 6 Revision l t

Spent Fuel Pool Boron Concentration B 3.7.'15

~ BASES LC0l The spent fuel pool' boron concentration is required to be a 300 ppm for- the Holtec spent fuel pool storage racks and a:2000 ppm for the Joseph Oat spent fuel pool storage racks, as applicable. The specified .i

' concentration of dissolved boron in the spent fuel pool: preserves the assumptions used in the analyses of

.the potential critical accident scenarios as described in References 3.-4, 5. and 6c The dissolved boron concentration of 2000 ppm is the minimum required concentration for fuel assembly storage and movement I within the spent fuel pool for the Joseph Oats spent fuel pool storage racks. The dissolved boron .

concentration of 300 ppm bounds the minimum required concentration for accidents' occurring during fuel I assembly movement within the spent fuel pool for the i Holtec spent fuel. pool storage racks. During j installation of the' Holtec spent fuel pool storage )

racks, when both Joseph Oat and Holtec spent fuel pool storage racks are in the spent fuel pool, the more j

l restrictive of the two minimum boron concentration '

limits (i.e., 2000 pam) is required to be met. After removal of.all JosepT 0at spent fuel pool storage racks. only-the 300 ppm boron concentration limit is required to be met.

APPLICABILITY This LC0 applies whenever fuel assemblies are stored in the spent fuel pool.

The presence of soluble boron is assumed in the l criticality analyses and is credited for ensuring that spent fuel pool k ,, will be maintained s 0.95 at a 95% confidence le, vel for all accident conditions and storage configurations-(for Joseph Oat spent fuel storage racks only). The 2000 ppm minimum boron concentration is also an initial condition in the spent fuel pool dilution analysis for the Joseph Oat spent ruei pool storage racks. Therefore, the restriction on soluble boron concentration in the spent fuel pool water must be maintained at all times wher fuel assemblies are stored in the spent fuel i pool.

i 1

l BRAIDWOOD - UNITS 1 & 2 B 3.7.15 - 7 Revision j

n Spent Fuel Pool Boron Concentration B 3.7.15 BASES-ACTIONS -The ACTIONS have been modified by a Note indicating

-that LCO 3.0.3 does~not. apply. '

A.] and A.2t When the concentration of boron in the spent' fuel 2001 is less than required. immediate action must be tacen

-to preclude the occurrence.of an' accident.or-to mitigate the consequences of- an accident in progress.

This is most efficiently achieved by immediately suspending the movement of fuel assemblies. This does not preclude movement of a fuel assembly to a safe position. Immediate actions are also taken to restore spent fuel pool. boron concentration. l If moving = fuel' assemblies while in MODE 5 or 6.

LC0 3.0.3 would not specify any action. If moving fuel assemblies while in MODES 1. 2. 3 and 4. the fuel movement is independent of reactor operations.

Therefore inability to suspend movement of fuel assemblies is not sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.7.15.1 REQUIREMENTS This SR verifies that the concentration of boron in i the spent fuel pool is within the required limit. As long as this SR is met, the analyzed accidents are fully addressed.

The 7 day frecuency is appropriate based on operating l experience anc takes into consideration that no major replenishment of pool water is expected to occur over such a short period of time.

REFERENCES 1. WCAP-14416-NP-A " Westinghouse Spent Fuel Rack Criticality Analysis Methodology." Rev. 1. dated November 1996.

2. NRC Memorandum from L. Kopp to T. Collins, dated August 19. 1998. " Guidance on the Regulatory Requirements for Criticality Analysis of Fuel Storage at Light Water Reactor Power Plants."

l BRAIDWOOD - UNITS 1 & 2 B 3.7.15 - 8 Revision

1 I

Spent Fuel Pool Boron Concentration i B 3.7.15 i l

BASES REFERENCES (continued)

3. CAC-97-162 " Byron and Braidwood Spent Fuel Rack l Criticality Analysis Using Soluble Baron Credit." dated May, 1997.
4. Holtec International Report. HI-982094

" Criticality Analysis for the Cyron/Braidwood Rack Installation Project." Project No. 80944, 1998.

5. UFSAR. Section 15.7.4. l
6. " Byron /Braidwood Spent Fuel Pool Dilution .l Analysis." Rev. 3. dated June 17, 1997.
7. Double contingency principle of ANSI N16.1 - l 1975. as specified in the April 14, 1978 NRC letter (Section 1.2) and implied in the proposed revision to Regulatory Guide 1.13 (Section 1.4 Appendix A).
8. ANSI /ANS 8.1 - 1983 "American National Standard for Nuclear Criticality Safety in Operations with Fissionable Materials Outside Reactors."
9. Safety Evaluation Report (SER) dated October 25, l 1996, issued by the Office of Nuclear Reactor i Regulation for Topical Report WCAP-14416-NP-A

" Westinghouse Spent Fuel Rack Criticality ]

1 Analysis Methodology."

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Spent Fuel Pool Boron Concentration B 3.7.15 l

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l BRAIDWOOD - UNITS 1 & 2 B 3.7.15 - 10 Revision l

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r Spent Fuel Assembly Storage B 3.7.16 B 3.7.' PLANT SYSTEMS- .

B 3.7.16.. Spent Fuel Assembly. Storage

. BASES.  !

-BACKGROUND The spent fuel pool provides for storage of various Westinghouse Optimized ruel Assembl different initial fuel enrichments'y and (OFA) types of.

exposure histories in two distinct regions. (For this discussion.-the term'0FA is intended to' refer to the specific reduced fuel rodlet diameter and includes i all analyzed fuel types with this diameter, such as '

Vantage 5.) In addition during the installation of Holtec spent fuel pool storage racks, both Holtec and Joseph Oat spent fuel pool racks will be in the spent fuel pool. At. the completion of installation, only Holtec spent- fuel pool storage racks wi.ll be in the spent fuel pool .There are 23 separate Jose h 0at 3 spent fuel pool storage racks which provide lacement locations for a total of 2870 new or used fu 1 f assemblies. Included in this are six specific storage i locations.in one of the racks-for placement of. failed fuel-assemblies. These locations are identified as the failed. fuel storage cells. Of these 23 racks. [

four are designated " Region 1" with the remaining 19 g racks designated as " Region 2". The analytical '

methodology used to develop the criticality analyses has been reviewed and approved by the NRC (Ref.1). 1 The 23. Joseph Oat spent fuel pool storage racks will

.be replaced with 24 Holtec spent fuel pool storage racks. which provide placement locations for a total of 2984 new or used fuel assemblies. Of these 24 Holtec spent fuel pool storage racks, four are -

designated " Region 1" with the remaining 20 racks designated as " Region 2." The analytical methodology used for the criticality analyses is in accordance i with established NRC guidelines (Ref. 2). J Joseoh Oat Soent Fuel Pool Storaae Racks l Region 1 racks contain 392 cells which are analyzed i for storing Westinghouse 0FAs in an "All Cells" arrangement (that is, the criticality analysis assumes

-that spent fuel assemblies reside in all available cell locations, with the exception of the boundary requirements).

~

The stored fuel assemblies may contain I an initial nominal enrichment of s 4.7 weight percent J U-235 (without Integral Fuel Burnable Absorbers

'BRAIDWOOD UNITS 1 & 2 B'3.7.16 Revision l

FT

}

j Spent Fuel Assembly Storage I B 3.7.16 l BASES I i

BACKGROUND (continued)

(IFBAs) installed) up to an initial nominal enrichment j of 5 5.0 weight percent U-235. provided that the  !

requirement for a minimum number of 16 IFBAs is met ,

(Ref. 3). The IFBAs are required to have, as a i minimum, a boron loading of 1.0X equal to an amount of 1.5 mg B"/ inch. This is the minimum standard poison material loading offered by Westinghouse for 17X17 0FAs.

Region 2 racks contain 2472 cells which are also analyzed for storing Westinghouse OFAs in a l combination of storage configurations. These patterns .  !

are:

1) "All Cells" Storage:
2) "3-out-of-4 Checkerboard" Storage: and
3) "2-out-of-4 Checkerboard" Storage. j For the "All Cells" storage configuration, the stored fuel assemblies may contain an initial nominal enrichment of s 1.14 weight percent U-235 (without taking credit for fuel burnup or radioactive decay of fuel constituents) up to an initial nominal enrichment j of 5 5.0 weight percent U-235, when fuel burnup and  ;

radioactive decay of fuel constituents are credited. l 1

For the "3-out-of-4 Checkerboard" storage  !

configuration, the stored fuel assemblies may contain i an initial nominal enrichment of 5 1.64 weight percent .

U-235 (without taking credit for fuel burnup or radioactive decay of fuel constituents) up to an initial nominal enrichment of s 5.0 weight percent U-235, when fuel burnup and radioactive decay of fuel constituents are credited. In this storage 3attern, there can be no more than three stored assem) lies in any 2X2 matrix of cell lattices.

For the "2-out-of-4 Checkerboard" storage configuration. the stored fuel assemblies may contain an initial nominal enrichment of s 4.10 weight percent U-235 (without taking credit for fuel burnup) up to an initial nominal enrichment of s 5.0 weight percent U-235, when fuel burnup is credited. In this storage pattern, no two fuel assemblies may be stored " face adjacent" (that is, there must be an empty cell opposite each face of the fuel assembly).

BRAIDWOOD - UNITS 1 & 2 B 3.7.16 - 2 Revision l

u

  1. . Spent Fuel Assembly Storage

. B 3./.16

" BASES

BACKGROUND'(continued)

Holtec Soent Fuel Pool Storaae Rack's Region 1 racks contain 396 cells which are analyzed for storing Westinghouse 0FAs in an "All Cells" arrangement (that is, the criticality' analysis assumes that spent fuel assemblies reside in all available cell. locations). The stored fuel assemblies may contain an initial . nominal enrichment of s 5.0 weight percent U-235 (with or_without Integral Fuel Burnable Absorbers-(IFBAs) installed) (Ref.-4).

Region 2 racks contain 2588 cells which are also analyzed for storing Westinghouse 0FAs in an "All Cells" arrangement (that is.'the criticality analysis assumes that spentifuel . assemblies reside in all available cell locations). For the "All Cells" storage configuration. the stored fuel assemblies may contain an initial nominal enrichment of s 5.0 weight percent U-235 with credit for burnup.

The water in the s)ent fuel pool normally contains soluble boron whic1 results in large subcriticality margins under actual operating conditions.

~ APPLICABLE NRC approved methodologies we're used to SAFETY ANALYSES develop the criticality analyses for the' Joseph Oat

-spent fuel pool stordge racks (Ref. 1) and methodologies in accordance with established NRC guidelines were used to develop the criticality analyses (Ref. 2) for the Holtec spent fuel pool storage racks. The fuel handling accident analyses are described in Reference 5. The accident analyses for criticality and spent fuel-pool dilution (for the Joseph Oat spent fuel storage racks only) are provided in References 3. 4. and 6. respectively.

The criticality analyses for the spent fuel assembly storage racks confirm that k remains < 1.0. for the Joseph Oat spent fuel pool st,o, rage racks, and s 0.95, for the Holtec spent fuel pool storage racks (including uncertainties and tolerances) at a 95%

3robability with a 95% confidence level (95/95 basis).

Jased on the accident condition of the pool being

<BRAIDWOOD - UNITS 1 & 2 B 3.7.16 - 3 Revision l

4

Spent Fuel As'sembly Storage B 3.7.16 ,

'I

BASES-

} 1

' APPLICABLE SAFETY ANALYSES.(continued)'

flooded with unborated water. Thus, the design'of both regions assumes the use of unborated water while.

maintaining stored' fuel . in a subcritical condition.

However, the' presence of soluble boron has been- 1 credited to provide adequate safety margin to maintain .l s 0.95 (also on a j 95/95' basis) for all postulated accspent fuel assembly storage involving dropped or misloaded fuel' assemblies (for Lboth Holtec and Joseph Oat spent fuel pool storage racks) and loss of spent fuel pool temperature control (for the Joseph.0at spent fuel pool storage racks j only). Crediting the presence of soluble boron for :i mitigation of these scenarios is. acceptable based on~ J applying the " double contingency principle" which' states that there is no requirement to assume two unlikely,' independent, concurrent events to ensure protection against a criticality accident (Refs. 7 and 8 ) '.

The accident: analyses address the following five postulated scenarios:

1) fuel assembly drop on top of rack:
2) . fuel assembly drop between rack modules:
3) fuel assembly drop between rack modules and saent fuel pool wall:
4) clange in spent fuel pool water temperature; and
5) fuel assembly loaded contrary to placement restrictions.

Of these. only the last two have the capacity to

, increase reactivity beyond the analyzed condition, for ,

the Joseph Oat' spent fuel pool storage racks, and only '

scenarios 2. 3. and 5 have the capacity to increase

. reactivity for the Holtec spent fuel pool storage racks.

Calculations were performed, for the Joseph Oat spent fuel pool storage racks, to determine the reactivity change caused by a change in spent fuel pool water temperature outside the normal range (50 - 160 F).

For the change in spent fuel pool water temperature accident. a temperature range of 32 - 240 F is considered. In all cases, additional reactivity BRAIDWOOD - UNITS:1 & 2 B 3.7.16 - 4 Revision l

~

J

Spent Fuel Assembly' Storage B 3.7.16 l

BASES, LAPPLICABLE SAFETY ANALYSES (continued)

]

m margin is available to the 0.95 k,rr limit to allow for temperature accidents. 'The temperature change accident can. occur at any time during operation of the spent fuel pool,  ;

i Calculations were also performed, for the Holtec spent I fuel pool storage racks, for a spent fuel pool temperature of.4 C (39 F) which is well below the lowest normal operating temperature (50 F). Because the temperature coefficient of reactivity in the spent ]

< fuel pool is negative, temperatures greater than 4 C

. will result in a decrease in reactivity.

For the. fuel assembly misload accident, calculations were performed to show the largest reactivity increase caused by a Westinghouse 17X17 0FA fuel assembly misplaced into a Joseph Oat storage cell for which the l restrictions on location enrichment., or burnup are not satisfied. Calculations were also performed to show the largest reactivity increase' caused by a l Westinghouse 17X17 0FA fuel assembly mis) laced into a Holtec Region 2 storage cell for which t7e l

restrictions on enrichment or burnup are not satisfied. The assembly misload accident can only occur during fuel handling operations in the spent fuel pool.

For the above postulated accident conditions. the double contingency principh can be ap) lied.

Specifically. the presence of soluble )oron in the spent fuel pool water can be assumed as a realistic j initial condition since not assuming its presence would be a second unlikely. event. For the Joseph Oat spent fuel pool storage racks spent fuel pool soluble boron has been credited in the criticality safety analysis to offset storage rack and fuel assembly tolerances, calculational-uncertainties, uncertainty associated with burnup credit and ae reactivity increase caused by postulated accidertt conditions.

For the Holtec spent. fuel pool _ storage racks, spent fuel pool soluble boron has been~ credited in the criticality safety analysis to offset the reactivity caused by postulated accider,c conditions. Because the Region 1 racks are designed for the storage of fresh fuel assemblies a fuel assembly misload accident has no consequences from a criticality standpoint (i .e. .

BRAIDWOOD -' UNITS 1 & 2 B'3.7.16 - 5 Revision l l

1.

y ,x h- _

Spent' Fuel Assembly Storage-B 3.7.16 1 BASES APPpCABLESAFETYANALYSES(continued)-

,- the. acceptance criteria for storage are satisfied by all assemblies _in the.. spent fuel pool).

-Based on the above discussion for the Joseph Oat' spent

-fuel pool storage-racks, should a spent fuel pool water temperature change accident or.a fuel assembly ~

misload ' accident: occur in the Region 1 Regian-2. or

.sfailed fuel storage cells, 'k,[r will be maintained:

0.95 due.to the presence o at least 550 ppm (no fuel ~ handling).or 1650 ppm (during fuel handling) of soluble boron in the spent fuel pool water. For the Holtec spent fuel pool storage racks,. should a fuel:

assembly misload accident occur in the Region 2 .

storage cells,tk will be maintained s 0.95 due to the- '

presence of at l,e,a,st 300 ppm of soluble boron in the spent fuel. pool water.

For the Joseph Oat. spent fuel pool storage' racks.-a spent fuel pool dilution analysis (Ref. 6) has been -

performed as required by Reference 9. The analysis assumes an initial boron concentration of.2000 ppm.

LThe dilution analysis concludes-that an unplanned or.

inadvertent event that would result in the dilution.of-the spent fuel' pool boron concentration from 2000 ppm to 550 ppm (minimum non-accident boron concentration) is not credible.

Interface requirements (for the Joseph Dat spent fuel-pool storage racks only) have been established to ensure k,,, is maintained within the appropriate limits.

There are interface requirements between Region 1 racks, between Region 1 and Region 2 racks between Region 2 racks. and within racks between different checkerboard configurations. These requirements are necessary to account for unique geometries and configurations which exist _ at the interfaces.

Interface requirements exist between adjacent racks to account for the potential-reactivity increase in 3-out-of-4 and 2-out-of-4 storage configurations along the interface with non-aligned: racks, The configuration of fuel assemblies in the spent fuel pool satisfies Criterion 2 of 10 CFR 50,36(c)(2)(ii).

4 BRAIDWOOD'- UNITS'1 & 2 B 3.7.16 - 6 Revision l

m .

' Spent Fuel Assembly Storage B 3.7.16.

BASES I

LCO The restrictions on the placement of fuel assemblies

.within the spent fuel pool in accordance with the

. requirements-in the accompanying LC0 ensure that the-k,ft of the' spent fuel pool will always remain < 1~.0 assuming the pool is flooded with unborated water and' s 0.95 assuming the presence of 550 ppm soluble boron '

in the

' racks, and poolsfor-the Joseph Oat 0.95 assuming the spent pool isfuel pool with flooded storage unborated water for the Holtec spent fuel pool storage racks.

For the Joseph Oat spent fuel pool storage racks, in [

LC0 Figures 3.7.16-1 and 3.7.16-2, the Acceptable Burnup Domain lies on, above, and to the left of the. decay-time line applicable to the fuel assembly to be stored. The decay time for that assembly is measured from the time since the assembly was last discharged.

For the-Joseph Oat spent fuel-pool storage racks, in l LC0 Figure 3.7-.16-3, the Acceptable Burnup Domain and the Unacceptable Burnup Domain are separated by a single line because decay time is not credited in the 2-out-of-4 Checkerboard storage configuration. The Acceptable Burnup Domain lies on, above, and to the left of the line.

In each figure, the use of linear inter between minimum burnups is acceptable. polation For the Holtec spent fuel pool storage racks, in LCO Figure 3.7.16-4, the Acceptable Burnup Domain lies on, i above, ynd to the left of the burnup versus enrichment line.

APPLICABILITY This LCO applies whenever fuel assemblies are stored in the spent. fuel pool.

I I

IBRAIDWOOD-UNITS 1&2 B 3.7.16 - 7 Revision I

Spent Fuel Assembly Storage B 3.7.16 BASES ACTIONS The ACTIONS have been modified by a Note indicating that LCO 3.0.3 does not apply.

A.1 When the configuration of fuel assemblies stored in I the spent fuel pool is not in accordance with the requirements of the LCO. immediate action must be taken to make the necessary fuel assembly movement (s) to bring the configuration into compliance.

l If moving fuel assemblies while in MODE 5 or 6.

LCO 3.0.3 would not specify any action. If moving .

fuel assemblies while 4.n MODES 1. 2. 3. and 4. the fuel movement is independent of reactor operations.

Therefore, inability to suspend movement of fuel assemblies is not sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.7.16.1 REQUIREMENTS Item a and item b are performed, as applicable, prior l to storing the fuel assembly in the intended spent  !

fuel pool storage location. The frequency is '

a)propriate because compliance with the SR ensures tlat the relationship between the fuel assembly and its storage location will meet the requirements of the LCO and preserve the assumptions of the analyses q

This SR verifies by administrative means that the initial nominal enrichment of the fuel assembly (for both Holtec and Joseph Oat spent fuel pool storage racks) or a minimum number of 16 IFBAs (for Joseph Oat s)ent fuel pool storage racks only) is met to ensure tlat the assumptions of the safety analyses are preserved.

SR 3.7.16.1 has been modified by a Note indicating that item a is only applicable for storage of fuel assemblies in Region 1 Holtec spent fuel pool storage racks, and item b is only applicable for storage of fuel assemblies in Region 1 Joseph Oat spent fuel pool storage racks.

BRAIDWOOD - UNITS 1 & 2 B 3.7.16 - 8 Revision l l

a m ' Spent Fuel. Assembly Storage B - 3. 7. '16 .

BASESL ESURVEILLANCE REQUIREMENTS ~(continued)

~ .SR '3;7.16.2 SR 3.7.16.2 is performed prior to storing the fuel assembly in'the intended spent fuel pool storage location. . The frequency is appropriate because-compliance with the SR ensures that the relationship ,

, between the fuel assembly and its storage location will meet the requirements of the LCO'and preserve the assumptions of-the analyses.

This SR verifies by administrative means.that the combination of initial enrichment, burnup, and decay time, as applicable. 'of the fuel assembly is within ]

the Accepta)le Burnup Domain of Figure 3.7.16-1.

3.7;16-2.:3.7.16-3.' or 3.7.16-4 for the intended. _l storage configuration to ensure that the assumptions of the safety analyses are preserved.

~

SR 3.7-.16,2'has been modified by a Note indicating that' Figures 3.7.16-1, 3.7.16-2, and 3.7.16-3'are only applicable..for storage of fuel assemblies'in Region 2 Joseph Oat spent fuel pool storage racks, and Figure 3.7.16-4 is only applicable for storage of fuel assemblies in Region 2 Holtec' spent fuel pool storage ,

racks'.

j SR- 3.7.16.3 l SR 3.7.16.3 is performed prior to storing the fuel assembly in the intended spent fuel-pool. storage location The frequency is appropriate because compliance with the SR ensures.that the relationship 3 between the fuel assembly and its storage location )

will, meet -the requirements of the LCO and preserve the '

assumptions-of the analyses.

This SR verifies by administrative means that the interface requirements-(Ref. 2) within and between adjacent 1 racks are met to ensure that the assumptions of the' safety analyses are preserved.

'SR 3.7.-16.3 has been modified by a Note' indicating that this SR is only applicable for storage of fuel assemblies in-Joseph Oat spent fuel pool storage racks. 4 l

BRAIDWOOD - UNITS 1 & 2 B 3.7.16 - 9 Revision l 4-

n Spent Fuel Assembly Storage B 3.7.16 q

~

~ BASES 4

-REFERE'NCES: 1.' 'WCAP-14416-NP-A " Westinghouse Spent Fuel Rack-Criticality Analysis Methodology." Rev 1. dated November 1996.

2 .- NRC Memorandum from L. Kopp to T.' Collins dated '

August 19. 1998. " Guidance on the' Regulatory '

Requirements for Criticality Analysis of Fuel  !

Storage at Light Water. Reactor Power Plants."

3. .CAC-97-162 " Byron and Braidwood Spent Fuel Rack l Criticality Analysis Using Soluble Boron Credit."  ;

' dated May. 1997;

.c 4 Holtec International Report. HI-982094. I

" Criticality Analysis for the Byron /Braidwood

' Rack Installation Project." Project'No. 80944. l 1998.

5. UFSAR. Section 15.7.4. l
6. " Byron /Braidwood Spent Fuel Pool'Oilution I Analysis." Rev. 3, dated June 17. 1997. l
7. Double conting  !

1975.asspecihncy.principleofANSIN16.1-ied in the April 14 . 1978 NRC letter (Section 1.2) and implied in the proposed revision to Regulatory Guide 1.13 (Section 1.4 )

Appendi.x A).

8. ANSI /ANS 8.I'- 1983 "American National Standard l for Nuclear Criticality Safety in Operations with Fissionable Materials Outside Reactors."
9. Safety Evaluation Report (SER) dated October 25. l 1996, i.ssued by the Office of Nuclear Reactor Regulation for Topical Report WCAP-14416-NP-A

" Westinghouse Spent. Fuel Rack Criticality Analysis Methodology."

l BRAIDWOOD . UNITS'1'& 2 .B 3.7.16 Revision l l

6

ATTACHMENT B 4 INCORPORATED PROPOSED CHANGES TYPED PAGES BYRON STATION REVISED PAGES 3.7.15-1 3.7.16 -1 3.7.16- 2 3.7.16- 3 3.7.16-4 3.7.16 -5 3.7.16 -6 3.7.16 - 7 4.0 - 2 4.0 - 3 REVISED BASES PAGES B 3.7.15-1 through B 3.7.15-10 8 3.7.16-1 through B 3.7.16-10 l

l 1

l

'1 B-4

~

w

~ Spent Fuel Pool Baron Concentration 3.7.15 3.7;PLANTSYSTEMS I

13.7.15 Spent Fuel-Pool BoroniConcentration  !

l J

[LCO 3.7.15 1The spent-fuel pool boron concentration shall be, as '

applicable:

-a. = 300 ppm for Holtec spent. fuel pool storage racks: and

b. :2 2000 ppm for Joseph Oat ~ spent fuel pool .;

storage racks. i

~

APPLICABILITY: Whenever fuel assemblies are stored in the spent fuel pool.

{

' ACTIONS-NOTE -

LCO 3.0.3..is not applicable.

l

. CONDITION REQUIRED ACTION COMPLETION TIME i i

A'. Spent fuel' pool boron A.1 Suspend movement of Immediately concentration nat fuel assemblies in

-within limit. the spen'. fuel pool .

AND A.2 Initiate action to Immediately restore spent fuel pool boron concentration to within limit.  !

l l

SURVEILLANCE REQUIREMENTS j

, . SURVEILLANCE FREQUENCY SR 3.7.15'.1 Verify 'the. spent fuel pool boron 7 days ..

concentration is within limit.

I l

SYRON UNITS 1 & 2 3.7.15 - 1 Amendment l

Spent Fuel Assembly Storage

_ 3.7.16

. - 3 7 ' PLANT SYSTEMS 13.7.16 . Spent Fuel Assembly Storage

- LC0 '3.7.16. Each s shall, pent; fuel assembly stored in the spent-fuel pool as applicable:

.a. Region 1 of; Joseph Oat spent fuel pool ' storage racks Have an initial nominal enrichment of s 4.7 weight aercent U-235 or satisfy a minimum number of Integral r

uel Burnable Absorbers (IFBAs) for higher initial enrichments up to 5.0 weight percent U-235 to permit storage in any cell location,

b. Region 2 of Joseph Oat spent ' fuel pool storage racks Have a combination of initial enrichment. burnup, and

-decay time within the Acceptable Burnup Domain of Figure 3.7.16-1~, 3.7.16-2, or 3.7.16-3, as applicable for that storage configuration.

c. Interface' Requirements for Joseph Oat spent fuel pool storage racks Comply with the Interface Requirements within and between adjacent racks,
d. Region 1 of Holtec spent fuel pool storage racks Have an initial nominal enrichment of 5 5.0 weight percent:U-235 to permit storage in any cell location.
e. Region 2 of the Holtec spent fuel pool storage racks Have a combination of initial enrichment and burnup within the Acceptable Burnup Domain of Figure 3.7.16-4.

. APPLICABILITY: Whenever fuel assemblies are stored in the spent fuel pool.

( ,.

L iBYRON'- UNITS'1.& 2- 3.7.16 - 1 Amendment l L

-se

Spent Fuel Assembly Storage 3.7.16 ACTIONS

--NOTE LC0 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME

~A. Requirements of the A.1 Initiate action to Inmediately .

LCO not met. move the noncomplying fuel assembly into a-location which restores compliance.

I SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.16.1 -

NOTE' Item a is only applicable for storage of fuel assemblies in Region 1 Holtec spent-fuel pool storage racks. Item b is only

. applicable for storage of fuel assemblies in Region 1 Joseph Oat spent fuel pool storage racks.

. Verify by administrative means the Prior to following requirements are met: storing the fuel assembly i

a. Initial nomina 1' enrichment of the in Region 1 1 fuel assembly is s 5.0 weight-percent U-235.

AND

b. Initial nominal enrichment of the i fuel assembly is s 4.7 weight percent  !

U-235 with less than the minimum number of '3As or s 5.0 weight percent U-?J5 with tne minimum number of IFBAs.

(continued)

BYRON - UNITS 1 & 2 1.7.16 Amendment l

p Spent Fuel Assembly Storage 3.7.16

. SURVEILLANCE REQUIREMENTS- (continued)

SURVEILLANCE- FREQUENCY SR'.;3.7.16.2 -

NOTE

- Figures 3.7.16-1. 3.7.16-2 and 3.7.16-3 are only applicable for storage of fuel assemblies in Region 2 Joseph Oat spent

- fuel pool' storage racks. Figure 3.7.16-4 is only applicable for storage of fuel assemblies in Region 2 Holtec spent fuel

- pool storage racks.

Verify by administrative means the Prior to combination of initial enrichment, burnep, storing the and decay time, as a)plicable, of the fuel fuel assembly assembly is within tie Acceptable Burnup in Region 2 Domain of Figure 3.7.16-1. 3.7.16-2, 3.7.16-3 or 3.7.16-4.

'SR; 3 7.16.3 -NOTE Only applicable for storage of fuel

- assemblies in Joseph Oat spent fuel pool storage racks.

Verify by administrative means the Prior to .

interface requirements within and between storing the adjacent racks are met. fuel assembly in the spent fuel pool 4

l BYRON - UffITS'.1 & 2 3.7.16 - 3 Amendment' l

Spent Fuel Assembly Storage 3.7.16 60000 , , , ,

, ; , i

i i , i ;

i , , DECAY i ! i i , ,

i i

i i , i i , ,

Tlh1E:

i i i i ,  ; i i ; i , 0 YEARS 55000

, , , j

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f

_i

~

i  ; .

! , e i . . i i i i if , 5 YEARS i

! i / ./

50000 '  ! i '

' '/> /

/ i/ /

10 YEARS i

ACCEPTABLE '

i , ,f, f y, 15 YEARS BURNUP DOA1AIN i !!! ff I ' / // 20 YEARS

, , , i i i 45000 , , , ,

i i

, j f f. f, f f -

y f ff ,

i i e i i i if fi fe // i l i i '  ! / / V // 6 i ! ! i i i i i /i / M // i i 40000 i t t i i /! / / // i '

i i

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W 20000

~

= i l

i '

/'f f f(

/ //#

i l

l l l i i  !

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! //g/ i ' >

I i i z 15000 "'# ' ' '

'A +

e// / ,

< i // / i t

t i

t t i

i i

. i i // / i i i i I i Q i I /// i i i i i i 10000  %,'f' ' , ,

ll , ,' l H -l l ffjf' '

UNACC'EPTABLE is: BURNUP DOh!AIN rl -

5000 l l lll

--[

l , ,

r . -

!  !  ! i i i r . . > . -  ! ' '

I '

! i i i i  !

O ' '

1.0 2.0 3 '. 0 4.0 5.0 INITIAL U-235 ENRICllhfENT (w/o)

Figure 3.7.16-1 (page 1 of 1)

Region 2'All Cell Configuration Burnup Credit Requirements (Joseph Oat Spent Fuel Pool Storage Racks) l

) BYRON - UNITS 1 & 2 3.7.16 - 4 Amendment l

Spent Fuel Assembly Storage 3.7:16 45000 , ,; ,,, , ,

i i i iii, iiii i, ,

'l l llll lll l,;l DECAY 40000 lll,i ME:

'l ll l'l! lii, 0 . EARS i i ! i;i i i i i i i iii ! i ' ' V 5 YEARS I i i , ! I i I ; I i i/j 3 35000 ' ' ' ' ' ' ' ' ' ' i ' v v. 10 YEARS 3 i  !-  ! i i i ! i i i ! i i i / // 15 YEARS 2

}

ACCEPTABLE

.BURNUP DOMAIN ,

ll i

l((/7f v yfa 20 YEARS 35 30000 p i ! -l  ! l  !

I i- ! ! / ////a i v l' I I I I I !/ / /// l 1

l i i i I V //#! i D

I i  ! I i  !  !///# i i i i i i i i i i/ //// l i i i z 25000 , i ; , , ,

, f fff , , ,

% i  ! i  ! iii I///# i  !

D i i i i -

i  ! / ////! I i C i i ! I i i//#/ i i i n 20000 , , , ll,l fyffll ' '#'

l E i i , ,

/ s // i i i i 7 l l l 1

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<  ! i i '

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E 10000 ' ' ' '

UhAbCEPTABL lll. g# BURNUP DOMAIN 5000 lll lll l'l i ! i l. i! I I

' i I ! i  !  !

!  ! I I I 0

!'/

l.0 2.0 3.0 4.0 5.0 INITIAL U-235 ENRICHMENT (w/o)

Figure 3.7,16-2 (page 1 of 1)

Region 2 3-out-of-4 Checkerboard Configuration Burnup Credit Requirements (Joseph Oat Spent Fuel Pool Storage Racks)

BYRON - UNITS 1 & 2 3.7.16 - 5 Amendment l

u  ;

i Spent Fuel Assembly Storage 3.7.16 )

)

5000'

' ll ll'! -

l-i !l !lI! i l il I. ij 'li ! ,

l l l [ i : ! i/

I I Li '/ {

4000 ll 1111 iLll ll } ! i if 1 I! ll1I I!II !III  :./> t g l' l dCbEPTABLE ii Il lI 1 g BURNUP DOMAIN l l l- /l  !! 1 k ll 1 ll / i E

e 3000 l I l-l lI I /1 I ll l i

1 I / lI,,! i  !

S II / Illl )

5 II  ! .i / 'll 5  !  !' I / l l

> l l  !  ! /

Ili l

= 2000 #

=

- ll i,L>; ll/ ' l -l 1 y i !!' I /! I i l 4 j Ii  ! /! l l

._: l- j l i i  :

/t j j I igog  !!l! / Il UNAbCEPT1BLE ll ll ll  !^!/  ! l l BURNUP DOMAIN l l; I ! -I-  :/  : :

I i' iI i

/  ! l

!! V i 1 0

4.0 4.2 .l . 4 4.6 4.8 5.0 INITIAL F-J' 35 ENRICliMENT (w/o)

Fi.gure 3.7.16-3 (page 1 of 1)

Region 2 2-out-of-4 Checkerboard Configuration

' Burnup Credit Requirements I (Joseph Oat Spent Fuel Pool Storage Racks) -  !

BYRON - UNITS 1 & 2 3.7.16 - 6 Amendment e

c ,

Spent Fuel Assembly Storage 3.7l16 45000 , , , , t , , , , , i , , .

, i- i i i i i i i < 1 ,

I l l l ! i i l i t

! I i i i i !

4.0000 l ll, l,, l1 , l ll,;',

i i1

, , , i, i i i t i i iiii r.

/

I i i l- i t i i l i i 1 if.  !

335000 p  !  !- I l !  ! i 1 ' 8

!/ 1 2 ' ! ' ' ' ' ' '

)530000 '

ACCEPTABLE BURNUP DOMAIN i l i' ' '

/l ll.',

w 2 i i i i i  ! /i i , ,i i

I ! l' I I / I I I ! ( i 1

I  ! I i I / i i i i i

! I I I i I i I  ! ! I i

/t

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,' lll C

4 iii i e i,i O

t iiI i i / i l i i ! i i l I . / i  ! ii 3

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)

lll l lffl

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4 ll i!

ll' I

ll, i 'i! i 7 i i i i i -- /iii t i j i iI Z ' I ! I i i i/ i i !  ! I I I i  ! I I !

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z15000

.'i i' ii ;!

.' >/ i i ,, i i i i; i i f, >

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C, j i I /! I i (

! t i i j

i i 310000 lll/ !

lj i i , , ll ll/ l;,  !' UNACCEPTABLE  !

i vi ! .

BURNUP DOMAIN i 5000 /' ii I 6 1 !

/' I I e i l 1 i i t i ! I i ! i t i, I I I  ! ! I i >

1 1 I i i i i i!

I ' ' ' ' '

' ' ' ' {

0  !

9

') 5

. 3 3.5 4 4.0 o INITIAL U-235 ENRICHMENT (w/o)

Figure 3.7.16-4 (page 1 of 1)

Region 2 Fuel Assembly Burnup Requirements (Holtec Spent Fuel Pool Storage Racks)

BYRON - UNITS 1 & 2 3.7.16 - 7 Amendment

Design Features 4.0 DESIGN FEATURES (continued) 4.3 Fuel Stor b.

4.3.1 Criticality The spt..t fuel storage racks are designed and shall be mainta'.ned, as applicable, with: l

a. Fuel assemblies having a maximum U-235 enrichment of 5.0 weight percent;
b. For Joseph Oat spent fuel pool storage racks. k ff < 1.0 if fully flooded with unborated water which includes an l allowance for uncertainties as described in WCAP-14416-NP-A. " Westinghouse Spent Fuel Rack -

Criticality Analysis Methodology":

c. For Joseph Oat spent fuel pool storage ryks. k,yr s 0.95 l if fully flooded with water borated to 550 ppm. which includes an allowance for uncertairties i as described in WCAP-14416-NP-A " Westinghouse Spant Fuel Rack Criticality Analysis Methodology";
d. For Joseph Oat spent fuel pool storage racks, a nominal 10.32 inch north-south and 10.42 inch east-west center to center distance between fuel assemblies placed in Region 1 racks:
e. For Jose)h Oat spent fuel pool storage racks. a nominal l 9.03 inci center to center distance between fuel assemblies placed in Region 2 racks.
f. s 0.95 if ForHoltecspentfuelpoolstorageracks.k,,iudesan fully flooded with unborated water which inc allowance for uncertainties as described in Holtec International Report. HI-982094. " Criticality Analysis for Byron /Braidwood Rack Installation Project." Project No. 80944. 1998:
g. For Holtec spent fuel 3001 storage racks, a nominal 10.574 inch north-sout1 and 10.888 inch east-west center to center distance between fuel assemblies placed in Region 1 racks: and
h. For Holtec spent fuel pool storage racks, a nominal 8.97 inch center to center distance between fuel assemblies placed in Region 2 racks. '

(continued)

BYRON - UNITS 1 & 2 4.0 - 2 Amendment l {

y-an Design Featur.es-4.0 DESIGN FEATURES (continued) 4.3.2 Drainaae The spent fuel pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 423 ft. 2 inches.

4.3.3 Caoacity The spent fuel pool is ' designed and shall be maintained with a storage capacity limited to no more than 2984 fuel assemolies.

BYRON - UNITS 1 & 2 4. 0 - 3 Amendment

mr k Spent Fuel Pool-Boron Concentration B 3.7.15

'B 3,7. PLANT SYSTEMS -

.B 3.'7.15 . Spent Fuel Pool Boron' Concentration -

! BASES ~

. BACKGROUND The spent fuel' pool provides for storage of various Westinghouse Optimized Fuel Assembly-(0FA)'. types of-different initial fuel l enrichments' and exposure histories in two distinct regions. (For this' . .

discussion the term 0FA is intended to refer to the specific reduced fuel rodlet diameter, and includes all analyzed fuel types with this diameter, such as Vantage 5.) . In addition, during the installation of Holtec spent fuel pool storage. racks, both Holtec and Joseph Oat spent fuel pool racks will be in the spent fuel pool. At the completion of. installation, only Holtec spent fuel pool storage racks will be in the spent fuel pool. There are 23 separate Jose h Oat spent fuel pool storage racks which provide lacement locations for a total of 2870 new or used fu 1

_ . assemblies. Included in this are six specific storage locations in one of the racks for. placement of failed fuel assemblies. - These locations are identified as -

the failed fuel storage cells. Of these 23 racks.

four are designated " Region 1" with the remaining 19 racks designated as " Region 2". The analytical methodology used to develop the criticality analyses has been reviewed and approved by the NRC (Ref.1).

The 23 Joseph Oat spent fuel pool storage racks will be' replaced with 24 Holtec spent fuel pool storage racks, which provide placement locations for a total of 2984 new or used fuel assemblies. Of the 24 Holtec spent fuel pool storige racks, four are designated

" Region 1" with the emaining 20 racks designated as

" Region 2." The ana;ytical methodology used for the criticality' analyses is in accordance with established NRC guidelines (Ref. 2).

-Joseoh Oat Soent Fuel Pool Storaae Racks 3 4

Region 1 racks contain 392 cells which are analyzed for sturing Westinghouse 0FAs in an "All Cells" arrangement (that is, the criticality analysis assumes 1 that spent fuel assemblies reside in all available l cell locations with the exception of the boundary requirements). The stored fuel assemblies may contain an initial nominal enrichment of s 4.7 weight percent 1 U-235 (without Integral Fuel Burnable Absorbers )

l BYRON - UNITS 1 & 2 B 3.7.15 - 1 Revision l

f Spent. Fuel Pool Boron Concentration B 3.7.15 BASES I LBACKGROUND (continued) i n .( IFBAs): installed) up to.an initial nominal enrichment of 5 5.0 weight percent U-235. provided.that the 1 requirement for a minimum number of 16 IFBAs is met i

(Ref. 3). The IFBAs are required to have. as a ]

r -

minimum. a boron loading-of 1.0X. equal to an amount

. of 1.5 mg B "/ inch. This is the minimum standard 2

! poison material loading offered by Westinghouse for 17X17 0FAs.

Region 2 racks contain 2472 cells which are also' I analyzed for storing Westinghouse OFAs in a combination of storage configurations. These patterns are:

1) "All Cells" Storage:
2) "3-out-of-4 Checkerboard" Storage; and
3) "2-out-of-4 Checkerboard" Storage.

For the "All Cells" storage configuration, the stored fueliassemblies may contain an initial nominal enrichment of s 1.14 weight percent U-235 (without taking credit for fuel burnup or radioactive decay of fuel constituents) up to an initial nominal enrichment of s 5.0 weight percent U-235 when fuel burnup and ,

radioactive decay of fuel constituents are credited.

For the "3-out-of-4 Checkerboard" storage configuration, the stored fuel assemblies may contain an initial nominal enrichment of 51.64 weight percent U-235 (without.taking credit for fuel burnup or radioactive decay of fuel constituents) up to an initial nominal enrichment of s 5.0 weight percent U-235, when fuel burnup and radioactive decay of fuel constituents are credited. In this storage aattern. ,

there can be no more than three stored assem31ies in  ;

any 2X2 matrix of cell lattices.

For the "2-out-of-4 Checkerboard" storage configuration, the stored fuel assemblies may contain an initial nominal enrichment of s 4.10 weight percent i U-235 (without taking credit for fuel burnup).up to an initial nominal enrichment of s 5.0 weight percent U-235. when fuel burnup is credited. In this storage pattern no two fuel assemblies may be sto ed " face adjacent'" (that is, there must be an empty cell opposite each face of the fuel assembly).

BYRON - UNITS'1 & 2 B 3.7.15 - 2 -

Revision

]

Spent Fuel Pool Boron Concentration B 3.7.15 BASES BACKGROUND (continued)

Holtec Soent Fuel Pool Storace Racks Region 1 racks contain 396 cells which are analyzed for storing Westinghouse OFAs in an "All Cells" arrangement (that is, the criticality analysis assumes that spent fuel assemblies reside in all available cell locations). The stored fuel assemblies may contain an initial nominal enrichment of s 5.0 weight percent U-235 (with or without Integral Fuel Burnable Absorbers (IFBAs) installed) (Ref. 4).

Region 2 racks contain 2588 cells which are also analyzed for storing Westinghouse 0FAs in an "All '

Cells" arrangement (that is, the criticality analysis assumes that spent fuel assemblies reside in all available cell locations). For the "All Cells" storage configuratica, the stored fuel assemblies may contain an initial nominal enrichment of s 5.0 weight percent U-235 m .n credit for burnup.

The water in the spent fuel pool normally contains soluble boron whicn results in large subcriticality margins under actual operating conditions.

APPLICABLE NRC approved methodologies were used to develop SAFETY ANALYSES the criticality analyses for the Joseph Oat spent fuel pool storage racks (Ref. 1) and methodologies in accordance with established NRC guidelines were used 4 to develop the criticality analyses (Ref. 2) for the Holtec spent fuel pool storage racks. The fuel handling accident analyses are described in Reference 5. The accident analyses for criticality and spent fuel pool dilution (for the Joseph Oat spent l fuel storage racks only) are provided in References 3. l

4. and 6, respectively.

The criticality analyses for the spent fuel assembly I storage racks confirm that k remains < 1.0. for the JosephOatspentfuelpoolskerorage racks, and s 0.95, for the Holtec spent fuel pool storage racks -

(including uncertainties and tolerances) at a 95%  ;

3robability with a 95% confidence level (95/95 basis). 1 aased on the accident condition of the pool being j BYRON - UNITS 1 & 2 B 3.7.15 - 3 Revision l

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Spent Fuel Pool Boron Concentration j B 3.7.15 :1

' BASES I

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l APPLICABLE SAFETY ANALYSES (< continued) j flooded with unborated water. -Thus, the design of both regions assumes the use of unborated water while j maintaining stored-fuel in a subcritical condition.

However, the presenc' e of soluble boron has been

'; credited to provide adequate safety margin to maintain

. spent fuel. assembly-storage rack-k m s 0.95 (also on a

'95/95' basis) for all postulated accident scenarios involving dropped or misloaded fuel assemblies (for both Holtec and Joseph Dat s ent fuel pool storage racks) and loss of spent fue pool temperature control (for the Joseph Oat spent fuel pool storage racks i only). Crediting the presence of soluble boron for mitigation of these scenarios is acceptable based on applying the. " double contingency principle" which states that there is no requirement to assume two unlikely.. independent concurrent events to ensure protection against a criticality accident (Refs. 7 and 8). j The accident analyses address the following five postulated scenarios:

1) fuel assembly drop on top of rack:
2) fuel assembly drop between rack modules:
3) fuel assembly drop between rack modules and s)ent fuel pool wall: 4
4) c1ange in spent fuel pool water temperature: and
5) fuel assembly loaded contrary to placement restrictions.

Of these, only the last two have the capacity to increase reactivity beyond the analyzed condition, for

'the Joseph Oat spent fuel pool storage racks., and only scenarios 2. 3. and 5 have the capacity to increase reactivity for the Holtec spent fuel pool storage racks. >

' Calculations were performed, for the Joseph Oat spent fuel pool storage racks, to determine the reactivity change caused by a change in spent fuel pool water temperature outside the normal range (50 - 160 F),

For the change in spent fuel pool water temperature

accident, a temperature range of 32 - 240 F is  !

considered. In all cases., additional reactivity I

BYRON - UNITS 1 &L2 B 3.7.15 - 4 Revision l

{

l 1

m Spent Fuel Pool' Boron Concentratjon-B 3.7.15 BASES APPLICABLE SAFETY ANALYSES (continued)-

1 margin ~is available to the 0.95 k,,, limit to allow for

~

j

= temperature accidents. The temperature ~ change accident can occur at any time during operation of the spent' fuel pool.

. Calculations were also performed.' for the Holtec spent fuel pool storage racks. for a spent fuel pool o . temperature of 4 C (39 F) which is well below the.

lowest normal operating temperature (50 F). Because

- the temperature coefficient of- reactivity in the spent fuel pool is negative. temperatures greater than 4 C will result in a decrease in reactivity.- -

For the fuel assembly misload accident, calculations were performed to show the largest vity reactivity increase caused by a Westinghouse 17X17 0FA .

fuel assembly misplaced into a Joseph Oat storage cell l j for'which.the restrictions on location, enrichment, or j burnup are not satisfied. Calculations were also i

. performed to show the largest reactivity increase caused by a Westinghouse 17X17 0FA fuel assembly.

misplaced into a Holtec Region 2 storage cell for which the restrictions on ~ enrichment or burnup are not satisfied. The assembly misload accident can only occur during fuel handling operations in the spent fuel pool.

For the above postulated accident conditions, the l double contingency principle can be ap) lied. .

Specifically, the presence of soluble )oron-in the spent fuel pool water can be assumed as a realistic 1

initial condition since not' assuming its presence )

would be a second unlikely event. For-the~ Joseph Oat i spent fuel pool storage racks, spent fuel pool soluble boron has been credited in the criticality safety ,

analysis to offset storage rack and fuel assembly {

tolerances, calculational uncertainties, uncertainty associate (' with burnup credit and the reactivity )

increase caused by postulated accident conditions.  !

For the Holtec spent fuel pool storage racks, spent l fuel pool soluble boron has been credited in the I criticality safety analysis to offset the reactivity )

caused by postulated accident conditions. Because the I Region 1 racks are designed for the storage of fresh fuel' assemblies a fuel assembly misload accident has {

l no consequences from a criticality standpoint (i .e. , j BYRON - UNITS 1-& 2 B 3.7.15 - 5 Revision l j

Spent Fuel Pool Boron Concentrati.on B 3.7.15 BASES' APPLICABLE SAFETY ANALYSES (continued) the acceptance criteria for storage are. satisfied ~by all assemblies in the spent fuel pool).

Based on the.above discussion for the Joseph Oat spent fuel pool storage racks, should a spent' fuel pool water temperature change' accident or a fuel assembly misload accident occur in the Region 1. Region 2. or

  1. failed fuel storage cells, k will be maintained s0.95duetothepresenceo, frat least 550 ppm (no -

fuel handling) or 1650. ppm (during fuel handling) of-soluble boron in~the spent fuel pool water. For the Holtec spent fuel pool storage racks, should a fuel assembly misload accident occur in the Region 2 storage cells, k,,, will be maintained s 0.95 due to the-presence of at least 300 ppm of soluble boron in the spent' fuel pool water.

For the Joseph Oat spent fuel pool storage racks, a spent fuel. pool dilution analysis (Ref. 6) has been performed as required by Reference 9. The analysis assumes an initial boron concentration of 2000 ppm.

The dilution analysis concludes that an unplanned or inadvertent event that would result in the dilution of the spent fuel pool boron concentration from 2000 ppm to 550 ppm (minimum non-accident boron concentration) is not credible.

Interface requirements (for the Joseph Dat spent fuel pool storage racks only) have been established to ensure k,,, is maintained within the appropriate limits. There are interface requirements between Region 1 racks. between Region 1 and Region 2 racks.

between Region 2 racks and within racks between different checkerboard configurations. These requirements are necessary to account for unique geometries and configurations which exist at the interfaces, Interface requirements exist between adjacent racks to account for the potential reactivity increase in 3-out-of-4 and 2-out-of-4 storage configurations along the interface with non-aligned racks.

The concentration of dissolved boron in the spent fuel pool satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

' BYRON,- UNITS.1 & 2 B 3.7.15 - 6 Revision l

p _~

3 Spent' Fuel Pool Boron Concentration B 3.7.15 p_ BASES LC0_ The' spent ' fuel pool boron concentration'is required to be a: 300 ppm fcr the Holtec spent ; fuel pool stora e racks and 2000 ppm for the Joseph Oat spent fue pool storage racks._as applicable. The .specified

. concentration of dissolved boron in the spent fuel pool preserves the assumptions used in the. analyses of the potential critical accident scenarios as described in References 3. 4. 5. and 6. The dissolved boron concentration of 2000 ppm is the minimum required ,

concentration for fuel assembly storage and movement within the spent fuel. pool for the Joseph Oats spent fuel pool storage racks. The dissolved boron concentration of 300 ppm bounds _ the minimum required concentration for accidents occurring during fuel assembly movement within the spent fuel pool for the Holtec spent fuel pool storage racks. During installation of the Holtec spent fuel pool storage racks, when both Joseph Oat and Holtec spent fuel pool storage racks are in the spent fuel pool, the more restrictive of the two minimum boron concentration limits (i.e. 2000 pam) is required to be met. After removal of all Josep1 Dat spent fuel pool storage racks, only the 300 ppm boron concentration limit is required to be met.

APPLICABILITY This LC0 applies whenever fuel assemblies are stored I in the spent fuel pool.

The presence of soluble boron is assumed in the l criticality analyses and is credited for ensuring that spent fuel pool k n will be maintained s 0.95 at a 95% confidence le, vel for all accident conditions and storage configurations (for Joseph Oat spent fuel storage racks only). The 2000 ppm minimum boron concentration is also an initial condition in the spent fuel " "ilution analysis for the Joseph Dat spent fur ,torage racks. Therefore the f !

restriction va soluble boron concentration in the spent fuel pool water must be maintained at all times when fuel assemblies are stored in the spent fuel l pool.

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BYRON - UNITS 1 & 2 B 3.7.15 - 7 Revision

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Spent Fuel Pool Boron Concentration B 3.7 15 BASESn n

ACTIONS TheiACTIONS-have been modified by a Note indicating that LCO 3.0.3 does not apply.

.A.1 and A.2-When the concentration of baron in the spent fuel 3001

.is-less than, required. immediate action must be tacen to preclude the occurrence of an accident or to

~ mitigate the consequences of an accident.in progress.

! This is most' efficiently achieved by immediately suspending the movement of fuel assemblies. This does .

' not preclude movement of a fuel assembly to a safe position. Immediate actions are also taken to restore spent fuel pool boron concentration.

If moving fuel assemblies while in MODE 5 or 6.

LCO 3.0.3 would not specify any action. If moving fuel assemblies while in MODES 1. 2. 3. and 4. the fuel movement is independent of reactor operations.

Therefore, inability to suspend movement of fuel l- assemblies is not sufficient reason to require a j reactor shutdown.

l L

SURVEILLANCE SR 3.7.15'.1 REQUIREMENTS This SR verifies that the concentration of boron in j

the spent fuel pool is within the required limit As long as this SR is met, the analyzed accidents are {

fully addressed. j The 7 day frecuency is appropriate based on operating experience anc takes into consideration that no major replenishment of pool water is expected to occur over  ;

such a short period of time. j REFERENCES 1. WCAP-14416-NP-A " Westinghouse Spent Fuel Rack Criticality Analysis Methodology." Rev. 1. dated November. 1996.

2. NRC Memorandum-from L. Kopp to T. Collins, dated l August 19. 1998. " Guidance on the Regulatory Requirements for Criticality Analysis of Fuel Storage at Light Water Reactor Power Plants."

BYRON'-_ UNITS 1 &-2 B 3.7.15 - 8 -

Revision l

Spent Fuel Pool Boron Concentration B 3.7.15

~ BASES REFERENCES (continued)

3. CAC-97-162 " Byron and Braidwood Spent Fuel Rack l Criticality Analysis Using Soluble Boron Credit." dated May, 1997.

-4. Holtec International Report. HI-982094

" Criticality Analysis for the Byron /Braidwood Rack Installation Project." Project No. 80944, 1998.

5. UFSAR. Section 15.7.4. l
6. " Byron /Braidwood Spent Fuel Pool Dilution l-Analysis." Rev. 3. dated June 17, 1997. ,
7. Double contingency principle of ANSI N16.1 - l 1975, as specified in the April 14, 1978 NRC letter (Section 1.2) and implied in the proposed revision to Regulatory Guide 1.13 (Section 1.4.

Appendix A).

8. ANSI /ANS 8.1 - 1983 "American National Standard for Nuclear Criticality Safety in 0]erations with Fissionable Materials Outside Reactors."

. 9. Safety Evaluation Report (SER) dated October 25. l 1996, issued by the Office of Nuclear Reactor Regulation for Topical Re) ort WCAP-14416-NP-A

" Westinghouse Spent Fuel Rack Criticality  ;

Analysis Methodology." j I

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J BYR0s - UNITS 1 &'2 B 3.7.15 - 10 Revision l I

Spent Fuel Assembly Storage B 3.7.16 i B 3.7 PLANT SYSTEMS.

B 3.7.16 Spent Fuel Assembly Storage BASES BACKGROUND The spent fuel pool provides for storage of various Westinghouse Optimized Fuel Assembly (OFA) types of different initial fuel enrichments and exposure histories-in two distinct regions. (For this discussion, the term 0FA is intended to refer to the specific reduced fuel rodlet diameter, and includes all analyzed fuel types with this diameter. such as Vantage 5.) In addition. during the installation of Holtec spent fuel pool storage racks, both Holtec and -

Joseph Oat spent fuel pool racks will be in the spent fuel pool. At the completion of installation, only Holtec spent fuel pool storage racks will be in the spent fuel pool. There are 23 separate Joseph Oat spent fuel pool storage racks which provide placement locations for a total of 2870 new or used fuel assemblies. Included in this are six specific storage locations in one of the racks for olacement of failed fuel assemblies. These locations are identified as the failed fuel storage cells. Of these 23 racks. l four are designated " Region 1" with the remaining 19 ,

racks designated as " Region 2". The analytical i methodology used to develop the criticality analyses j has been reviewed and approved by the NRC (Ref. 1). i The 23 Joseph Oat spent fuel pool storage racks will j be replaced with 24 Holtec spent fuel pool storage  ;

racks, which provide placement locations for a total of 2984 new or used fuel assemblies. Of these 24 Holtec spent fuel pool storage racks, four are designated " Region 1" with the remaining 20 racks designated as " Region 2." The analytical methodology used for the criticality analyses is in accordance with established NRC guidelines (Ref. 2).

Joseph Oat Soent Fuel Pool Storage Racks l Region 1 racks contain 392 cells which are analyzed for storing Westinghouse OFAs in an "All Cells"

, arrangement (that is, the criticality analysis assumes that spent fuel assemblies reside in all available l cell locations, with the exception of the boundary l requirements). The stored fuel assemblies may contain an initial nominal enrichment of s 4.7 weight percent U-235 (without Integral Fuel Burnable Absorbers

( BYRON - UNITS 1 & 2 B 3.7.16 - 1 Revision l i

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Spent Fuel Assembly Stor. age l B 3.7.16  !

l

.. BASES

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BACKGROUND.(continued) I (IFBAs) installed) up to an initial nominal enrichment

.of s 5.0 weight percent'U-235 provided that the

' requirement for a minimum number of 16 IFBAs is met

-(Ref. 3)-. The'IFBAs are required to have, as a l l

- minimum, a boron loading of 1.0X, equal to an amount

,- of 1.5 mg B '/ inch. This is the minimum standard poison material loading offered by' Westinghouse for 17X17 0FAs.

Region 2' racks contain 2472 cells which are also analyzed for storing Westinghouse'0FAs in a combination of storage configurations. These patterns are:

1) "All Cells" Storage:
2) "3-out-of-4 Checkerboard" Storage; and <
3) "2-out-of-4 Checkerboard"_ Storage.

For the "All Cells" storage configuration, the stored fuel assemblies may contain an initial nominal enrichment of s 1.14 weight percent U-235 (without taking credit for fuel burnup or radioactive decay of fuel constituents) up to an initial nominal enrichment of s 5.0 weight percent U-235. when fuel burnup and radioactive decay of fuel constituents are credited.

For the "3-out-of-4 Checkerboard" storage configuration, the stored fuel assemblies may contain an initial nominal enrichment of s 1.64 weight percent U-235 (without taking credit for fuel burnup or radioactive decay of fuel constituents) up to an' initial nominal enrichment of s 5.0 weight percent

, U-235, when. fuel burnup and radioactive decay of fuel j constituents are credited. In this storage ]attern.

.there can be no more than three stored assem)1ies in any 2X2 matrix of cell lattices.

For the "2-out-of-4 Checkerboard" storage configuration the stored-fuel assemblies may contain j an initial nominal enrichment of s 4.10 weight percent  !

U-235 (without taking credit for fuel burnup) up to an initial nominal enrichment of 5 5.0 weight percent U-235 when fuel burnup is credited. In this storage pattern no two fuel assemblies may be stored " face adjacent" (that is. there must be an empty cell opposite each face of the fuel assembly). ,

' BYRON - ONITS:1 & 2 - B 3.7 16 - 2 Revision l

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' Spent Fuel' Assembly Storage.

B 3.7.16

- BASES BACKGROUNDJ(continued)

Holtec Soent Fuel Pool Storaae Racks Region 1 racks contain 396 cells which are analyzed for storing Westinghouse OFAs in an "All Cells" arrangement:(that is, the criticality analysis assumes that spent fuel assemblies reside in all available cell locations). The stored fuel assemblies may contain .an initial nominal enrichment of 5 5.0 weight-percent U-235 (with or without-Integral-Fuel Burnable Absorbers-(IFBAs) installed) (Ref. 4).

Region 2 racks contain 2588 cells which are also analyzed for storing Westinghouse OFAs in an "All Cells" arrangement-(that is, the criticality analysis assumes that spent fuel assemblies reside in all available cell locations).. For the "All Cells" storage configuration.-the stored fuel assemblies may contain an initial nominal enrichment of s 5.0 weight percent U-235 with credit for burnup.

The water in the s)ent fuel pool normally contains soluble boron whic1 results in large subcriticality margins under actual operating conditions.

l APPLICABLE .NRC approved methodologies were used to ~l SAFETY ANALYSES develop the criticality analyses for the Joseph Oat spent fuel pool storage racks (Ref. 1) and methodologies in accordance with established NRC guidelines were used to develop the criticality analyses (Ref. 2) for the Holtec spent fuel pool storage racks. The fuel handling accident analyses are described in Reference 5. The accident analyses for criticality and spent fuel pool dilution (for the Joseph Oat spent fuel storage racks only) are provided  ;

in References 3. 4. and 6. respectively.

The criticality analyses for the spent fuel assembly storage racks confirm that k remains < 1.0. for the JosephOatspentfuelpoolstuorage racks, and 5 0.95.

l for the Holtec spent fuel pool storage racks (including uncertainties and tolerances) at a 95% l 3robability with a 95% confidence level (95/95 basis).

Jased on the accident condition of the pool being l

4 BYRON'- UNITS'1 & 2 B 3.7.16 - 3 ' Revision l

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E 1 Spent Fuel Assembly Storage

.B 3.7.16-

' BASES APPLICABLE SAFETY ANALYSES (continued) flooded with unborated water. Thus. the design of both regions assumes the use of unborated water while

. maintaining stored fuel in a subcritical condition.

However, the presence of soluble boron has been

. credited to provide adequate safety margin to maintain s s 0.95 (also on a 9 bent fuel 'assembl' storage rack-k,,ident scenarios

/95' basis)foraklpostulatedacc involving dropped or misloaded fuel assemblies (for l l both Holtec and' Joseph Oat spent fuel pool storage racks) and loss of spent fuel pool temperature control (for the Joseph Oat spent fuel pool storage racks only). Crediting the presence of soluble boron for mitigation of these scenarios is acceptable based on applying the " double contingency principle" which states that' there is no requirement to assume two unlikely, independent, concurrent events to ensure protection against~a criticality accident (Refs 7 and 8).

The accident analyses address the following five postulated scenarios:

1) fuel assembly drop on top of rack:
2) fuel assembly drop between rack modules:
3) fuel assembly drop between rack modules and s3ent fuel pool wall;
4) clange in spent fuel pool water temperature:

and

5) fuel assembly. loaded contrary to placement restrictions, Of these. only the last two have the capacity to increase reactivity beyond the analyzed condition, for the Joseph Oat spent fuel pool storage racks, and only scenarios 2. 3. and 5 have the capacity to increase reactivity for the Holtec spent fuel pool storage racks.

Calculations were performed, for the Joseph Oat spent fuel pool storage racks, to determine the reactivity change caused by a change in spent fuel pool water temperature outside the normal range (50 - 160 F).

For the change in spent fue' pool water temperature accident a temperature range of 32 - 240 F is  ;

considered. In all cases, additional reactivity BYRON.- UNITS-1 & 2 B 3.7.16 - 4 Revision

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3 Spent Fuel Assembly Storage l B 3.7.16 BASES

. APPLICABLE SAFETYLANALYSES-(continued)-- .

i margin is available to the 0.95 km limit to allow for '

' temperature accidents

. . The temperature change accident can' occur-at any time'during operation of the H spent fuel pool.

Calculations were also performed, for the Holtec. spent 1 fuel pool storage racks. for a spent fuel pool

.-temperature of 4 C'(39 F)-which-is well-below the lowest normal-operating temperature (50 F). Because the temperature coefficient of reactivity in the spent fuel pool'is negative, temperatures-greater than 4 C l

will result in a decrease in reactivity. I For the fuel assembly misload accident, calculations were performed to show the largest reactivity increase ]J caused by a Westinghouse 17X17 0FA fuel assembly j misplaced. into a Joseph Oat storage cell for which the J restrictions on location, enrichment. or burnup are l not satisfied. Calculations were also performed to l show the largest reactivity increase caused by a j Westinghouse 17X17 0FA fuel assembly mis) laced into a l Holtec Region 2 storage cell for which tie -

restrictions-on enrichment or burnup are not satisfied. The assembly misload accident can only f

. occur during fuel handling operations in the spent j fuel pool.

For the above postulated accident conditions, the double contingency principle can be ap) lied, i Specifically, the presence of soluble )oron in the i spent fuel pool water can be assumed as a realistic initial condition since not assuming its presence would be a.second unlikely event. For the Joseph Oat  !

spent fuel pool storage racks spent fuel pool soluble i boron has been credited in the criticality safety analysis to offset storage rack and fuel assembly tolerances, calculational uncertainties, uncertainty associated with burnup credit aN the reactivity increase caused by. postulated accident conditions.

For the Holtec spent fuel pool storage racks, spent fuel pool soluble boron has been credited in the criticality safety analysis to offset the reactivity caused by postulated accident conditions. Because the ion 1 racks are designed for the storage of fresh Reg'l fue assemblies, a fuel assembly misload accident has  !

l no consequences from a criticality standpoint (i.e..

- BYRON - UNITS 1 & 2 8 3.7.16 - 5 Revision l 1

9

r Spent Fuel Assembly Storage B 3.7.16 BASES APPLICABLE SAFETY ANALYSES (continued) the. acceptance criteria for storage are satisfied by all assemblies in the spent fuel pool).

Based on the above. discussion for the Joseph Oat spent fuel pool storage racks should a spent fuel pool

-water temperature change accident or a fuel assembly

'misload accident occur in the Region 1. Region 2. or will be maintained ,

sfailedfuelstoragecells,k,/,atleast550 0.95 due to the presence o ppm (no fuel handling) or.1650 ppm (during fuel handling) of soluble boron in the spent fuel pool- water. For the Holtec spent fuel pool storage racks. should a fuel assembly misload accident occur in the Region 2 storage cells, k rr will be maintained s 0.95 due to the presence of at l, east 300 ppm of-soluble boron in the spent. fuel pool water.

Fcr the Joseph Oat spent fuel pool storage racks, a spent fuel pool dilution analysis (Ref. 6) has been performed as required by Reference 9. The analysis assumes an initial boron concentration of 2000 ppm.

The dilution analysis concludes that an unplanned or inadvertent event that would result in the dilution of the spent fuel pool boron concentration from 2000 ppm to 550 ppm (minimum non-accident boron concentration)

-is not credible.

. Interface requirements.(for the Joseph Oat spent fuel pool' storage racks only.) have been established to ensure k There ar,rr is maintained e interface withinbetween requirements the appropriate Region 1limits.

racks, between Region 1 and Region 2 racks, between Region 2 racks and within racks between different checkerboard configurations. These requirements are necessary to account for unique geometries and configurations which exist at the interfaces.

Interface requirements exist between adjacent racks to ,

' account-for the potential reactivity increase in {

out-of-4 and 2-out-of-4 storage configurations along j the interface with non-aligned racks. j The configuration of fuel assemblies in the spent fuel pool satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii). j l

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e Spent Fuel Assembly Storage B 3.7.16 BASES-

-LCO The restrictions on the placement of fuel assemblies within the spent fuel pool in'accordance with the requirements in'the accompanying LC0 ensure that the k,,, of. the spent fuel pool will always remain < 1.0 assuming the pool is flooded with unborated water and s 0.95' assuming the presence of 550 ppm soluble boron in the pool .for the Joseph Oat spent fuel pool storage racks.-and s 0.95 assuming the pool is flooded with unborated water for the Holtec spent fuel pool storage' racks.

For the Joseph Oat spent fuel pool storage racks, in -l LC0 Figures-3.7.16-1 and 3.7.16-2.-the -

Acceptable Burnup Domain lies on, above, and to the left of the decay time line applicable to the fuel assembly to be stored. The decay time for that assembly'is measured from the time since the assembly was last discharged.

For the Joseph Oat spent fuel pool storage racks. in LC0 Figure 3,7.16-3. the Acceptable Burnup Domain and the Unacceptable Burnup Domain are separated by a single line because decay time is not credited in the 2-out-of-4 Checkerboard storage configuration. The Acceptable Burnup Domain lies on, above, and to the left of the line.

In each figure the use of linear interpolation between minimum burnaps is acceptable.

For the Holtec spent fuel pool storage racks, in LCO Figure 3.7.16-4. the Acceptable Burnup Domain lies on. '

above. and to the left of the burnup versus enrichment line.

APPLICABILITY. This LC0 applies whenever fuel assemblies are stored in the spent-fuel pool.

i j

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BYRON -l UNITS 1-& 2 B 3.7.16 - 7 Revision

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L , l Spent Fuel Assembly Storage  :

B 3.7'16 -l i

~ BASES

, ACTIONS: The ACTIONS have been modified by a Note indicating that.LC0 3.0.3 does not apply.

, b.l

-When the configuration; of fuel assemblies stored in the spent fuel pool.is not in accordance with the requirements of the LCO,:immediate action must be taken to make the necessary fuel assembly movement (s) to bring the configuration into compliance. -

If~ moving fuel assemblies while in MODE 5 or 6.

LC0 3.0.3 would not specify any action. If moving fuel assemblies while in MODES 1. 2, 3. and 4. the

~ fuel movement is independent of reactor operations.

Therefore. inability to suspend movement of fuel assemblies is not sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.7.16.1 REQUIREMENTS Item a and item b are performed, as applicable. prior to storing the fuel 2 assembly in the intended spent fuel pool storage location. The frequency is a)propriate because compliance with the SR ensures tlat.the relationship between the fuel assembly and its storage: location will meet the requirements of the

, LCO and preserve the assumptions of the analyses.

This SR verifies by administrative means that the initial nominal enrichment of the fuel assembly (for both Holtec and Joseph Dat spent fuel pool storage racks) or a minimum number of 16 IFBAs (for Joseph Oat s)ent fuel pool storage racks only) is met to ensure tlat the assumptions of the safety analyses are preserved, SR 3.7.16.1 has been modified by a Note indicating that item a .is only applicable for storage of fuel assemblies -in Region 1 Holtec spent fuel pool storage racks. and item b is only applicable for storage of I

- fuel assemblies in Region 1 Joseph Oat spent fuel pool j storage racks.

e i ?0N - ONITS 1 &l2~ .B 3.7;16.- 8 Revision  !

Spent Fuel Assembly Storage 9

B 3.7.16 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3 7.16.2 SR 3.7.16.2 is ' performed prior to storing the . fuel

, assembly in the intended spent fuel pool storage location. The frequency is appropriate because compliance with the SR ensures that the relationship.

between the fuel assembly'and its storage location will meet the requirements of. the LC0 and preserve the assumptions of the analyses.

This SR verifies by ~ admin'istrative means that tha combination of.. initial enr.ichment, burnup, and decay i time as ap)licable, of the fuel assembly is within I the Accepta)le Burnup Domain of F1gure 3.7.16-1.

3.7.16-2, 3.7.16-3 or 3.7.16-4 for the intended l storage configuration to ensure that the assumptions of the safety analyses are preserved.

I SR 3 7.16.2 has been modified by a Note indicating that Figures 3.7.16-1, 3.7.16-2, and 3.7 17-3 are only applicable for storage of fuel assemblies in Region 2 Joseph Oat spent fuel pool storage racks, anc' Figure 3.7.16-4 is only applicable for storage of ftel assemblies in Region 2 Holtec spent fuel pool storage racks.

SR 3.7.16.3 SR 3.7.16.3 is performed prior to storing the fuel assembly in the intended spent fuel pool storage location. 'The frequency is appropriate because compliance with the SR ensures that the relationship between the fuel assembly and its storage location will meet the requirements of the LCO and preserve the assumptions of the analyses i

This SR verifies by administrative means that the  !

interface requirements (Ref. 2) within and between l adjacent racks are met to ensure that the assumptions of the safety analyses are preserved.

SR 3.7.16.3 has been modified by a Note indicating that this SR is only applicab!e for storage of fuel assemblies in Joseph Oat spent fuel pool storage racks.

BYRON'- UNITS =1 & 2 B 3.7.16'- 9 Revision

7 Spent Fuel Assembly-Storage B 3.7.16

. BASES REFERENCES- 1. WCAP-14416-NP-A " Westinghouse Spent Fuel Rack -

Criticality Analysis Methodology." Rev. 1. dated November. 1996.

2. NRC Memorandum from L. Kopp to T. Collins, dated

' August 19, 1998. " Guidance on the Regulatory-Requirements for Criticality Analysis of Fuel Storage at. Light Water Reactor Power Plants "

3. CAC-97-162 " Byron and Braidwood Spent Fuel Rack l Criticality Analysis Using Soluble Boron Credit,"

dated May, 1997.

4. Holtec International Report. HI-982094

" Criticality Analysis for the Byron /Braidwood Rack Installation Project." Project No. 80944, 1998.

5. UFSAR. Section 15.7.4.
6. " Byron /Braidwood Spent Fuel Pool Dilution l Analysis." Rev. 3. dated June 17, 1997.
7. Double contingency principle of ANSI.N16.1 - l 1975.. as specified in the April,14,1978 NRC letter (Section 1.2) and implied in the proposed revision to Regulatory Guide 1.13 (Section 1.4 Appendix A).
8. ANSI /ANS 8.1 - 1983 "American National Standard l for Nuclear Criticality Safety in Operations with Fissionable Materials Outside Reactors."
9. Safety Evaluation Report (SER) dated October 25. l 1996.. issued by the Office of Nuclear Reactor Regulation for Topical Report WCAP-14416-NP-A

" Westinghouse Spent Fuel Rack Criticality Analysis Methodology."

LBYRON - UNITS 1 & 2 B 3.7.16 - 10 Revision l

e ATTACHMENT C INFORMATION SUPPORTING A FINDING OF i NO SIGNIFICANT HAZARDS CONSIDERATION The proposed changes to Technical Specifications 3.7.15, Spent Fuel Pool Boron ,,

Concentration"; 3.7.16, " Spent Fuel Assembly Storage"; 4.J.1, " Criticality"; and 4.3.3,

" Capacity"; support installation of new Boral high-density spent fuel pool storage racks at the Byron and Braidwood Stations. These proposed changes willinvolve removing all 23 of the existing Joseph Oat spent fuel storage racks at each station and replacing them with 24 new Holtec spent fuel storece racks.

' The existing racks utilize Boraflex as the neutron absorber material. Degradation of Boraflex has caused water chemistry and clarity problems and has also resulted in the need I to rely on soluble boron in the spent fuel pool to maintain the design basis. The new spent fuel storage racks utilize Boral as the neutron absorber material. Boralis a boron carbide aluminum cermet and has been used successfully at numerous plents in the United States, Korea, Mexico, Brazil, and the United Kingdom. Installation of these new racks will also increase the spent fuel pool storage capacity at Byron and Braidwood Stations from 2870  ;

assemblies to 2984 at,semblies.

According to 10CFR 50.92 (c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

Involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated; (

i Create the possibility of a new or different kind of accident from any previously analyzed, or; I involve a significant reduction in the margin of safety. l In support of this determination, an evaluation of each of the three criteria set forth in 1.0 CFR 50.92 is provided below.

l The proposed Technical Specifications (TS) changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

During the installation of the new Holtec spent fuel pool storage racks, both Holtec and the eristing Joseph Oat spent fuel pool storage racks will be in the spent fuel pool at the same -

time. This interim arrangement will not increase the probability or consequences of an accident previously evaluated. The criticality analysis for the Joseph Oat spent fuel pool storage racks states that should a spent fuel pool water temperature change accident or a fuel assembly misload accident occur in the Region 1, Region 2, or failed fuel storage cells, k,will be maintained s 0.95 due to the presence of at least 550 ppm (no fuel handling) or 1650 ppm (during fuel handling) of soluble boron in the spent fuel pool water. These assumptions are more conservative than the requirements 5,Wed in the criticality analysis for the Holtec spent fuel pool storage racks which only requires 2?0 ppm boror to maintain C-1

' k,s 0.95 during the worst case fuel assembly misload accident. The new Holtec racks have a superior neutron attenuation capability due to their improved design. The requirement of 2000 ppm boron will be maintained during the entire change out process, I therefore, ensuring that k,will remain 5 0.95. At the completion of installation, only Holtec spent fuel pool storage racks will be in the spent fuel pool.

The previously evaluated Byron and Braidwood Stations accidents relative to spent fuel storage are discussed in the Updated Final Safety Analysis Report (UFSAR) Section 15.7.4,

" Fuel Handling Accidents," and UFSAR Section 15.7.5, " Spent Fuel Cask Drop Accident."

These accidents were considered for the new Holtec spent fuel pool racks and are listed below.

a. Spent fuel assembly dropped onto the spent fuel pool floor. '
b. Spent fuel assembly dropped between racks.
c. Spent fuel assembly dropped between a' rack and the spent fuel pool wall.
d. Spent fuel assembly loaded contrary to placement restrictions.
e. Spent fuel assembly dropped onto to a rack.
f. Spent fuel cask drop.
g. Change in spent fuel pool water temperature.

Spent Fuel Assembly Dropped onto the Spent Fuel Pool Floor The probability and consequences of dropping a spent fuel assembly onto the spent fuel pool liner have been evaluated and shown to be bounded by the existing design basis as .

described in the Byron and Braidwood Stations UFSAR. The maximum drop distance for a fuel assembly will not change as a result of.this design change and, therefore, the consequences of this fuel handling accident remain unchanged. The probability of this fuel handling accident is not changed by the installation of new Holtec spent fuel pool storage

' racks or by the small increase (approximately 4.0 %) in spent fuel storage capacity as the spent fuel handling procedures and equipment are unaffected by the change. Also, the number of spent fuel assemblies is not an input to the initial conditions of this accident evaluation.

Spent Fuel Assembly Dropped Between Racks The probability and consequences of dropping a fuel assembly between rack modules was previously evaluated under UFSAR Section 9.1.2.3.9, " Accident / Abnormal Storage Conditions in Spent Fuel Pool Racks," which supports TS Limiting Condition for Operation (LCO) 3.7.15 and was shown to have no effect on reactivity. This is considered a bounding analysis and is applicable to this design change since the new Holtec rack layout still precludes a reactivity increase due to this fuel handling accident. The probability of this event is unaffected due to the similarity between the new Holtec spent fuel pool rack layout and the existing Joseph Oat spent fuel pool rack layout.

Spent Fuel Assembly Dropped Between a Rack and the Spent Fuel Pool Wall The probability and cce1 sequences of dropping a spent fuel assembly between a rack module and the spe.it fuel wall has been evaluated for the new Holtec spent fuel pool racks.

The worst case scenario consists of a fresh fuel assembly, of the highest allowed enrichment, accidentally placed in a cut out area between a rack and the new fuel elevator or tool bracket. The consequences of this event remain within the design basis criticality C-2

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.] 1 limit of s 0.95 k,, assuming a minimum soluble boron concentration of 220 ppn; in the spent fuel pool water. The probability of this event is unaffected due to the similarity j between the new Holtec spent fuel pool rack layout and the existing Joseph Oat spent fuel pool rack layot.t. This event is bounded by the analysis of misloading an assembly into a Region 2 rack, discussed below.

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_ Spent Fuel A'ssembly Loaded Contraiy to Placement Restrictions

' The probability and consequences of loading a fuel assembly contrary to placement restrictions has been evaluated fd the Holtec racks. A worst case 'cenario of placing a fuel

. assembly of the highest enrichment (i.e.,5.0 weight percent U-235) into a Region 2 rack cell was shown to remain within the design basis criticality limit of 0.95 k,, assuming a minimum soluble boron concentration of 220 ppm in the spent fuel poa water. The current required soluble boron concentration in the spent fuel poolis 2000 ppm. The minimum soluble boron concentra'Jon, proposed in conjunction with this det!gn change, is 300 ppm for conservatism. The probability of this event is unaffected by this design change since the ,

existing pool already includes a two region layout, similar to the new Holtec racks. Further, the possibility of a misloaded fuel assembly is minimized by an independent verification of the Nuclear Component Transfer List that prescribes the exact location of each fuel assembly. After an assembly is placed in a spent fuel pool storage cell, station personnel once again independently verify it.

Spent Fuel Assembly Dropped onto to a Rack The probability and consequences of dropping a spent fuel assembly onto a spent fuel storage rack have been evaluated for the Holtec racks. The consequences are shown to meet all existing design basis requirements as described in the Byron and Braidwood Station UFSAR. Analyses of the spent fuel drop accidents onto the top of a spent fuel pool storage rack (shallow drop), and a deep drop into the bottom of a cell, resulting in impact at the bottom of the rack cell, were performed to demonstrate that the spent fuel rack retains its structural ir.tegrity and capability to safely store spent fuel in adjacent cells. The damage due to a perfectly vertical drop, on the top of a rack, bounds an inclined fuel assembly drop because the impact energy is focused on a single cell wall, which results in maximum cell I t, lockage. The radiological consequences of the drop onto the spent fuel poolliner, shallow .

drop onto to the top of the rack, and deep drop into the bottom of a rack cell, are bounded by the existing UFSAR assumptions that 314 fuel rods rupture. The UFSAR design basis dose is shown to be much less than the 10 CFR 100 off-site dose limits of 300 rem to tN thyroid and 25 rem to the whole body. The probability of these fuel handling accidents occurring is unaffected by the installation of new spent fuel storage racks. The spent fuel handling procedures and equipment are unaffected by this change and therefore there is no increase in the probsbility of these fuel handling accidents.

Spent Fuel Cask Drop The probability and consequences of a cask drop were evaluated and shown to be unaffected by the replacement of the existing Joseph Oat spent fuel pool storage racks with Holtec racks. There are no changes to any of the systems, structures, components or equipment associated with the movement of a spent fuel cask. The cask is shown by the Byron and Braidwood Stations UFSAR to be isolated from the spent fuel pool by the combination of guard walls, which are designed to withstand the impact of a cask drop, and both administrative and physical controls. These controls are designed to preclude the fuel C-3

a handling building crane from traveling over the spent fuel pool. There are also trolley stops on the crane bridge which physically prevent the main book of the crane from traveling into the spent fuel pool storage area when handling a spent fuel cask. Spent fuel pool rack installation activities and cask handling will not be performed simultaneously, thus minimizing the possibility of improper movement of the cask. This practice is consistent with the Byron and Braidwood Stations UFSAR assumptions relative to new fuel operations.

Since there will be no changes to eny of the equipment, procedures or operations relative to spent fuel cask handling that are associated with this design change, there is no increase in the probability or consequences of this fuel handling accident.

Change in Spent Fuel Pool Water Temperature The probability and consequences of a change in the temperature of the spent fuel pool water was evaluated for the potential for an increase in reactivity. The new Holtec rack analysis was performed assuming a spent fuel pool water temperature of 4 C (39 F), which is well below the lowest normal operating temperature of 50 F. Because the reactivity temperature coefficient in the spent fuel pool is negative, temperatures greater than 4 C will result in a decrease in reactivity. The probability of this event is unaffected by the spent fuel pool rack replacement because there are no features of this design change affecting the spent fuel pool cooling system or that would prompt a spent fuel pool water temperature decrease.

Rack Installation Ho!tec International personnel will execute the construction phases of the Byron and Braidwood Stations rack installations. All construction work will be performed in compliance with Byron and Braidwood Stations' commitments to NUREG-0612 and site-specific procedures. Holtec International and Commonwealth Edison are developing a complete set of operating procedures which cover the entire gamut of operations pertaining to the rack installation effort. Similar procedures have been utilized and successfully implemented by Holtec International on previous rack installation projects. These procedures assure that ALARA practices are followed and provide detailed requirements to assure equipment, personnel, and plant safety.

Crane and fuel bridge operators will be adequately trained in the operation of load handling machines per the station specific training program. The lifting device designed for handling and installation of the new racks at Byron and Braidwood Stations is in compliance with the l provisions of NUREG-0612, including compliance with the primary stress criteria, load testing with a multiplier for maximum working load, and nondestructive examination of j critical welds.

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An intensive surveillance and inspection program shall be maintained throughout the rack l j

installation phase of the project. A set of inspection points has been established based on l

experience in numerous previous rack installation campaigns. These inspections have i proven to eliminate incidence of rework or erroneous installation.

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Based on the review of the accidents previously analyzed in the UFSAR, and considering )

the rigorous controls in place for installation of the new spent fuel pool storage racks, it is concluded that there will not be a significa: increase in the probability or consequences of an accident previously evaluated.

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The proposed TS changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

The replacement of the existing Byron and Braidwood spent fuel pool storage racks, having a capacity of 2870 cells, with new racks having a capacity of 2984 cells, was evaluated for the possibility of creating a new or different accident. The following cases were reviewed:

a. An accidental drop of a rack into the spent fuel poo!, and
b. Additional heat load resulting from the additional storage capacity.

A construction accident resulting in a rack drop is an extremely unlikely event. ' Operability of the cranes will be checked prior to use. Lift equipment and rigging will also be inspected prior to use. Operators of lift equipment and cranes will be trained prior to use. Safe load paths will be followed and Byron and Braidwood Stations' commitments to the provisions of NUREG-0612 will be implemented by use of written procedures that have been utilized for numerous other similar rack installation projects. The Technical Requirements Manual requires that Fuel Handling Building Crane loads be limited to 2000 pounds when traveling over fuel assemblies. This limitation will be adhered to during the entire coursr of rack installation, in the unlikely event of a rack drop, a leak chase system located beneath the spent fuel pool liner is capable of collecting and isolating the leakage. A rack drop would present limited structural damage to the spent fuel pool slab on grade, due to the slab being founded on rock and soil. Local concrete crushing and possible liner puncture could occur.

Failure of the liner would not result in a significant loss of water and no safety related equipment would be affected by the leakage. Make up water is available from 3 separate sources. There are two 500,000 galkm Refueling Water Storage Tanks, non-category 1 '

back up water sources, and the unboT.ad Safety Category 1 fire protection system, available for spent fuel pool water make up. A rack drop, therefore, does not create the possibility of creating a new or different kind of accident.

The additional heat load resulting from the additional storage capacity of 114 cells (i.e.,

approximately 4%) has been evaluated for the possibility cf creating a new or different kind of accident. The existing spent fuel pool cooling system has been shown to be capable of removing the decay heat generated by the additional spect fuel assemblies utilizing the standard Byron and Braidwood Stations operating procedures. Since it is shown that the spent fuel pool cooling system will maintain the spent fuel pool water tempernture within the i existing design basis, as detailed in the Byron and Braidwood UFSAR, it is concluded that the proposed changes do not create a new or different kind of accident.

Replacing the existing 23 Joseph Oat Boraflex racks with 24 new Holtec racks containing Boral, and increasing the spent fuel storage capacity in each of the spent fuel pools at Byron and Braidwood Stations to 2984 assemblies, will not create the possibility of an accident of a different type. The fuel pool rack and fuel configurations have been analyzed considering criticality, thermal hydraulic, and structural effects. The increase in storage capacity is achieved by the installation of additional racks of similar, but improved design, which are passive components. No new operating schemes or active equipment types will be required to store additional fuel assemblies in the fuel pools. The possibility of a different type of accident occurring is not created since the new racks meet or exceed the requirements applicable to the existing racks.

Therefore, implementation of the proposed TS changes do not create the possibility of a new or different kind of accident from any previously evaluated.

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The proposeo TS changes do not involve a significant reduction in a margin of safety.

The function of the spent fuel pool is to store fuel assemblies in a st; ) critical and coolable configuration throughout all environmental and abnormal loadings, so ch as earthquakes, ,

dropped fuel assemblies, or loss of spent fuel pool cooling. The new spent fuel storage {

racks are designed to meet all applicable requirements for safe stort je of spent fuel and 2 are functionally compatible with the spent fuel pool.

i The Holtec Licensing Report has analyzed the consequences of thi reracking project by area. In each area, (i.e., criticality, seismic, structural, thermal hydraulics, and radiological exposure), design basis margins of safety will be maintained. Installation controls specified j in Byron and Braidwood S'.ations' commitments to NUREG-0612 preserve the margins of i safety with regard to heavy load restrictions, Compliance with the Byron and Braidwood f Station design basis limits and procedure adherence will preclude reducing margins of safety.

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The margin of safety is not reduced as demonstrated by analysis'of the seismic, structural,

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thermal hydraulic, criticality, and radiological aspects of this design change. The Byron and j Braidwood Station design basis spent fuel pool maximum bulk temperature acceptance limit I of 140*F has been demonstrated to be preserved by analysis. Criticality calculations show that k, will be maintained at s 0.95. The new Holtec spent fuel pool storage racks have l

been designed in accordance with the Byron and Braidwood Station design bases j requirements and the NRC OT position paper. l Since all aspects of the design change have been demonstrated to be within the existing design bases for Byron and Braidwood Stations and the NRC requirements applicable to spent fuel storage, the proposed changes do not involve a significant reduction in the margin of safety.

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ATTACHMENT D INFORMATION SUPPORTING AN ENVIRONMENTAL ASSESSMENT l

Comed has evaluated this proposed operating license amendment consistent with the (

criteria for identification of licensing and regulatory actions requiring environmental  !

assessment in eccurdance with 10 CFR 51.21. Comed has determined that this proposed j license amendment meets the criteria for a categorical exclusion set forth in 10 CFR 51.22(c)(9) and as such, has determined that no irreversible consequences exist in  ;

accordance with 10 CM 30.92(b). This determination is based on the fact that this change {

is being proposed as an amendment to a license issued pursuant to 10 CFR 50 that changes a requirement with respect to installation or use of a facility component located {j within the restricted area, as defined in 10 CFR 20, or that changes an inspection or a I surveillance requirement, and the proposed amendment meets the following specific criteria. j (i) The proposed amendment involves no significant hazards consideration.

As demonstrated in Attachment C, this proposed amendment does not involve a significant hazards consideration.

(ii) There is no significant change in the types or significant increase in the )

amounts of any effluent that may be released offsite.

As documented in Attachmerit C, there will be no change in the types or significant i increase in the amounts of any effluents released offsite.

Solid 5ffluents The necessity for replacement of the resin in the spent fuel pori demineralizer is determined primarily by the requirement for water clarity. The resin is normally replaced approximately once a year. No significant increase in the volume of solid radioactive wastes is expected with the expanded storage capacity of 114 cells, which is a 4% increase from the existing capacity (i.e. an increase from 2870 cells to 2984 cells). During reracking operations, small amounts of additional waste resin may be generated by the pool cleanup systems on a one-time basis. i No effects are anticipated on non-radiological waste stream generation, specifically for air, wastewater, solid waste or hazardous waste, therefore, no changes to the j National Pollutant Discharge Elimination System permit are required.

Gaseous and Liauid Effluents 1

Gaseous releases from the Fuel Handling Building are combined with other plant exhausts. Normally, the contribution from the Fuel Handling Building is negligible I compared to the gaseous and liquid releases from other sources. No significant l increases are expected as a result of the minimal storage capacity expansion (i.e.,

114 storage cells or a 4% increase in storage capacity).

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l The storage of spent fuel assemblies does not directly affect the release of radioactive liquids from the plant, since radioactive liquids are not directly discharged from the spent fuel pool.

l (iii) There is no significant increase in individual or cumulative occupational {

radiation exposure.

There will be no change in the level of controls or methodology used for the processing of radioactive effluents or handling of solid radioactive waste, nor will the proposed changes result in any change in the normal radiation levels within the l

plant, Therefore, there will be no increase in individual or cumulative occupational f radiation exposure resulting from this change.

Total occupational exposure for the re-racking modification is estimated to be between 6 and 12 person-rem. While individual worker tasks and resultant exposures will differ, I the estimated total dose is consistent with previous rerack modifications.

During normal operations, personnel working in the fuel storage area are exposed to radiation from the spent fuel pool. The dose rates experienced by personnel are not expected to increase with the increased storage capacity of the Holtec racks because the dose rate from the fuelin storage is negligible. The water above the stored fuelis sufficiently deep such that the dose rate from that fuelis orders of magnitude lower than the dose rate contribution from the radionucFjes in the pool water itself.- Consequently, though the dose rate from stored fuel may increase slightly because more spent fuel assemblies may be stored in the pool, it will not increase to levels comparable to tho.se caused by the radionuclides in the pool water. i The radionuclide concentrations in the pool water are not expected to increase significantly. Radionuclide concentration levels are determined principally from the mixing of primary system water with the spent fuel pool water and crud dc,;osits from spent fuel assemblies moved into the storage pool during refueling operations.

Although the overall capacities of the pools are being increased, the number of fuel  ;

assemblies moved during refueling operations is independent of storage capacity.

Operating experience has shown that there have been negligible concentrations of airborne radioactivity and no increases are expected as a result of the expanded I storage capacities. Area monitors for airborne activities are available in the immediate vicinities of the spent fuel pools.

It is therefore concluded that there will be no increase in individual or cumulative occupational radiation exposura resulting from this change.

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