ML20211M316

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Requests That NRC Approve Requested Exemption from Requirements of 10CFR70.24, Criticality Accident Requirements, by 971105,to Avoid Impacting Util Plans for Receipt of Fresh Nuclear Fuel at DBNPS in Early 1998
ML20211M316
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 10/03/1997
From: Jeffery Wood
CENTERIOR ENERGY
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
2490, TAC-M97924, NUDOCS 9710140128
Download: ML20211M316 (7)


Text

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m usw.nw.e sie248-r3ao un.wooo Oak Ha' tor.OH 43449 FAX: die 3218337 V Pr sedert.Nucleaf Docket Number 50-346 License Number NPF 3 Serial Nurnber 2490 October 3. 1997 United States Nuclear Regulatory Conunission Document Control Desk Washington, D. C. 20$55 0001

Subject:

Additional Information for a Proposed Exemption from 10CFR70.24," Criticality Accident Requirements"(TAC No. M97924)

Ladies arid Gentlemen:

By letter (Scrial Number 2440) dated January 30,1997 Toledo Edison (TE) submitted a request for an exemption from the requirements of 10CFR70.24," Criticality Accident Requirements,"

for the Davis Besse Nuclear Power Station (DBNPS), Unit 1. By letter (Serial Number 2457) dated May 28,1997, TE provided additional information to the NRC with regards to the exemption request, in order for the NRC staff to complete the processing of the exemption request, the NRC staff requested by letter (TE leg Number 5111) dated July 31,1997, that TE provide a confirmation of adherence to five criteria. Toledo Edison's response is provided in the enclosure to this letter, With the providing of this information, TE requests that the NRC staff approve the requested exemption by November 5,1997, to avoid impacting TE's plans for receipt of fresh nuclear fuel at the DBNPS in early 1998. This fuel is required for loading into the reactor during the Spring, 1998 refueling outage, I

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1 9710140128 971003' PDR ADOCK 05000346 P

PDR

Docket Number 50 346 License Number NPF 3 Serial Number 2490

, Page 2 Should you have any questions or require additional information, please contact hir. James L.

Freels, Manager - Regulatory Affairs, at (419) 321 8466.

l Very truly yours,

'bD o DRW/laj l

enclosure A.13.11each, Regional Administrator, NRC Region 111 cc:

A. O. llansen, D13 1 NRC/NRR Project Manager S. Stasek, DB 1 NRC Senior Resident inspector Utility Radiological Safety 130ard

Docket Number 50-346 License Number NPF-3 Serial Number 2490

. Enclosure Pagei DAVIS BESSE NUCLEAR POWER STATION REQUEST FOR EXEh1PTION FROh! 10 CFR 50.74

" CRITICALITY ACCIDENT REQUIREh1ENTS" BESPONSB TO NRC REOUEST FOR ADDITIONAL INFORh1 ATION By letters dated January 30,1997 (letter Serial Number 2440) and hiay 28,1997 (letter Serial l

Number 2457), Toledo Edison (TE) submitted information to the NRC in support of an exemption from the requirements of 10 CFR 70.24," Criticality Accident Requirements," for the l

Davis Besse Nuclear Power Station (DBNPS), Unit 1. By letter (TE Log Number $111) dated i

July 31,1997, the NRC staff requested that TE provide a confirmation of adherence to five l

criteria. The following provides TE's response to the NRC staff's request.

NRC Criterion No.1:

The k-effective of the fresh fuel storage racks filled with fuel of the maximum permissible U 235 enrichment and flooded with pure water does not exceed 0.95, at a 95% probability,95%

confidence level.

TE Response to Criterion No.1:

Davis Desse Nuclear Power Station Operating License, Appendix A, Technical Specification (TS) 5.6.1.2.a requires:

"The new fuel storage racks are designed and shall be mr.intained with:

a. A ker quivalent to less than or equal to 0.95 when Hooded with unborated e

water, which includes a conservative allowance of 1% delta k/k for uncertainties as described in Section 9.1 of the USAR."

Section 9.1.1 "New Fuel Storage," of the USAR (copy previously submitted witt leder Serial Number 2440) states that the new fuel storage fr.cility is maintained to have a k-etfeghe of less than 0.95 when Gooded with unborated water and rows C and F empty. This analysis assumed that the fuel assemblics were uniformly lor.ded with 5.0 weight percent U 235 fuel rods.

Technical Specification 5.6.1.2.d limits the maximum initial enrichment of fuel assemblies to 5.0 weight percent U 235.

Toledo Edison's license ameetment application (letter Serial Number 2149) to the NRC dated June 23,1993, addressed the statistical uncertainties providing a 95% probability,95%

confidence level for the new fuel storage racks loaded with 5.0 weight percent U 235 fuel and the rows C and F empty. The NRC's Safety Evaluatior (Section 2.3) for the resultant License

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Docket Number 50 346 License Number NPF 3 Serial Number 2490 Enclosure Page 2 Amendment Number 181 (TE Log Number 4111) also addressed the 95% probability,95'/e confidence level.

Accordingly, the DBNPS meets the above NRC criterion as documented in TS 5.6.1.2.a and USAR 9.1.1 for new fuel in the new fuel storage racks.

NRC Criterion No. 2 i

If optimum moderation of fuel in the fresh fuel storage racks occurs when the fresh fuel storage racks are filled with low-density hydrogenous fluid, the k effective corresponding to this 4

optimum moderation does not exceed 0.98, at a 95% probability,95% confidence level.

'Di Responi,e to Criterion No. 2:

Davis Besse Nuclear Power Station Operating License, Appendix A, Technical Specification (TS) 5.6.1.2.b requires:

"The new fuel storage racks are designed and shall be maintained with:

b. A kerrequivalent to less than or equal to 0.98 when immersed in a hydrogenous " mist" of such a density that provides optimum moderatun (i.e., highest value of kerr), which includes a conservative allowance of 1% delta k/k for uncertainties as desuih:J in Section 9.1 of the USAR."

Section 9.1.1,"New Fuel Storage," of the USAR (copy previously submitted with letter Serial Number 2440) states that the new fuel storage facility is maintained to have a k-effective ofless than 0.98 if the storage ar:a is immersed in a hydrogenous " mist" producing optimum moderation and rows C and F empty. This analysis assumed that the fuel assemblies were uniformly loaded with 5.0 weight percent U 235 fuel rods. Technical Specification 5.6.1.2.d limits the maximum initial enrichment of fuel assemblies to 5.0 weight percent U 235.

Accordingly, the DBNPS meets the above NRC criterion as documented in TS 5.6.1.2.b and USAR 9.1.1 for new fuel in the new fuel storage racks.

NRC Criterion No. 3:

The k-effective of spent fuel storage racks filled with fuel of the maximum permissible U 235 enrichment and flooded with pure water does not exceed 0.95, at a 95% probability,95%

confidence level, i

Docket Number 50 346 License Number NPF 3 Serial Number 2490

. Enclosure Page 3 TE Resoonse to Criterion No. 3 Davis Besse Nuclear Power Station Operating License, Appendix A, Technical Specification (TS) 5.6.1.1.a requires:

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

a. A ker equivalent to less than or equal to 0.95 when Gooded with unborated water, which includes a conservative allowance of 1% delta k/k for calculation uncertainty.

Section 9.1.2," Spent Fuel Storage," of the USAR (copy previously submitted with letter Serial Number 2440) states that the spent fuel storage facility is maintained to have a k-effective of less than 0.95 for fuel assemblies when flooded with unborated water and using the checkerboarding requirements of TS 3/4.9.13. This analysis assumed that the fuel assemblics were unifonnly loaded with 5.0 weight percent U 235 fuel rods. Technical Specification 5.6.1.2.d limits the maximum initial enrichment of fuel assemblies to 5.0 weight peteent U-235.

Toledo Edison's license amendment application (letter Serial Number 2149) to the NRC dated June 23,1993, addressed the statistical uncertainties providing a 95% probability,95%

confidence level for the checkerboarded spent fuel storage racks loaded with 5.0 weight percent fuel. The NRC's Safety Evaluation (Section 2.4) for the resultant License Amendment Number 181 (TE Log Number 4111) also addressed the 95% probability,95% confidence level.

Accordingly, the DBNPS meets the above NRC criterion as documented in TS 5.6.1.1.a and USAR 9.1.2 for spent fuel in the spent fuel storage racks.

NRC Criterion No. 4:

The quantity of special nuclear material, other than nuclear fuel, stored on site in any given area is less than the quantity necessary for a critical mass, TE Resoonse to Criterion No. 4 The quantity of special nuclear material, other than nuclear fuel, that TE stores on site in any given area is less than the quantity necessary for a critical mass.

NRC Criterion No. 5:

The maximum nominal U 235 enrichment does not exceed 5 wt %

.1

Docket Number 50 346 License Number NPF 3 Serial Number 2490

, Enclosure Page 4 TE Respo 1se io Criterion No. 5 Davis Besse Nuclear Power Station Operating License, Appendix A. Technical Specifications (TS) 5.6.1.2.d kiits the use of the new fuel storage racks to receiving fuel assemblies having a maximum initlst enrichment of 5.0 weight percent U 235.

The DBNPS USAR new fuel storage (Section 9.1.1) and spent fuel storage (Section 9.1.2) analyses are also limited to a maximum initial enrichment of 5 weight percent U 235 fuel.

The NRC's Safety Evaluation for License Amendment Number 181 (TE Log Number 4111) approved the DBNPS storage of new and spent fuel with an initial enrichment of U 235 no greater than 5.0 weight percent.

Accordingly, the DBNPS meets the above NRC criterion as documented in TS 5.6.1.2.d and US AR Sections 9.1.1 and 9.1.2 for fuel.

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