ML20244D253

Informs That Util 890203 Submittal Provided Insufficient Info & Basis to Justify Absence of Physical Barriers in Spent Fuel Pool at Plant.No Support Found for Assertion That Expense Outweigh Benefit

ML20244D253
Person / Time
Site:	McGuire, Mcguire
Issue date:	06/08/1989
From:	Matthews D Office of Nuclear Reactor Regulation
To:	Tucker H DUKE POWER CO.
References
TAC-72999, TAC-73000, NUDOCS 8906160186
Download: ML20244D253 (3)

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UNITED STATES :

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g NUCLEAR REGULATORY COMMISSION

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WASHINGTON, D. C 20556 -

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' June 8i1989

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1 Docket Nos. 50-369

50-370-N Mr. H. B. Tucker, Vice President U

Nuclear. Production Department 1

Duke Power Company '

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j 422 South Church Streets

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{ Charlotte, North Carolina.

28242

SUBJECT:

SPENT FUEL STORAGE RACK BARRIERS (TACS-72999 and'73000)

By' letter of-February 3,.1989, you. indicated:that you have decided not to'-

implement your previous consitment to install physical barriers in the spent, a

fuel pool at McGuire Nuclear Station. The barriers were intended to prevent inadvertent storage of spent fuel assemblies in predetermined empty locations :

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of a " checkerboard" loading pattern. You.r commitment was made by letter, dated.

1 July 16,1984 and was.a significant factor in the basis for staff acceptance 5f J

the reracked spent fuel pool as stated in the staff SER for Unit 1 Amendment 35 l

and Unit 2 Amendment.16 dated September 24,11984

-Your position, as discussed-i in a 10 CFR 50.59 evaluation attached to the February 3,1989 letter, is that j

administrative controls are considered sufficient to ensure that non-qualified-fuel (i.e., fuel not having'a specified minimum burnup defined in the Technical-1 Specifications) is stored in a checkerboard configuration with every other.

f location vacant.

You further stste that the use of physical barriers =is impractical and that designing and manufacturing appropriate barriers would be an unnecessary expense.

The NRC has reviewed your submittal and finds' insufficient information and basis to justify the absence of the barriers. You did not address, for ex-ample, the consequences (decrease in subcriticality margin) of misloading of:

1 fuel assemblies in.the spent fuel racks. Our-concern for subtriticality margin -

is heightened by (but not limited to) the design deficiencies in the existing rack design as noted in LER 369/88-48. Accordingly, we find. insufficient basis

j for your 50.59 conclusion that failure to implement this commitment does' not j

constitute a significant change in a safety margin.

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]q With regard to'your claim that the use of physical barriers is' impractical, we; find that several plants have_ previously installed and are successfully utiliz-j ing such barriers. We find no support for your assertion that the expense of I

designing and manufacturing the barriers for Mc Guire would outweigh the benefit of their use, or that such use is unnecessary.

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' Mr. H.-B.-Tucker 4 It is our position that because of,the' potential' for hunan. error and the.

unknown potential for criticality, exclusive reliance on administrative proce-

dures in lieu of physical barriers does not provide adequate assurance that-excessive loss of subcriticality margin in the spent' fuel pool will be precluded.

' Fbreover, your intended change in 'connitment. requires prior ~ staff apprdval. We-request that ynu promptly provide:further justification for your position, or that' you ' reevaluate your position and advise us. of your revised plans to implement the

' original commitment. 'Your-response is requested.in advance of the scheduled July.5,1989 refueling outage for McGuire Unit 2 and should discuss any additional.

measures proposed to preclude inadvertent storage locations during the Unit 2 refueling outage.

This letter does not alter potential enforcement issues as may be associated with this matter.

Sincerely,

Original Signed By:

n o., n u a.....s 25M$h David B. Matthews, Director Project Directorate II-3 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation DISTRIBUTION:

mDocket: File g"g NRC"PDR'"""

Local PDR PDII-3 Reading S. Varga 14-E-4 G. Lainas 14-H-3 D. Matthews 14-H M. Rood 14-H-25 D. Hood 14-H-25 OGC (for inform. Only) 15-B-18 E. Jordan MNBB-3302 B. Grimes 9-A-2 ACRS(10)

P-315

[McGuireFile]

W. Hodges T. Collins 33H

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Mr. H. B.. Tucker.

Duke Power Company McGuire Nuclear Station l

CC Mr.LA.V. Carr, Esq.

Dr. John M. Barry Duke Power Company Department.of Environmental Health j

P. 0., Box 33189 Mecklenburg County 422 South Church Street 1200 Blythe Boulevard Charlotte, North Carolina ~28242 Charlotte, North Carolina 28203' County Manager of Mecklenburg County Mr. Dayne H. - Brown, Chief 720 East Fourth Street' Radiation Protection Branch Charlotte, North Carolina 28202 Division of Facility Services Department of.; Human. Resources 701 Barbour Drive Mr. J.'S. Warren Raleigh, North Carolina 27603-2008 Duke Power Company Nuclear Production Department-Mr. Alan R. Herdt, Chief, P. 0. Box 33189 Project Branch #3 Charlotte, North Carolina 28242-U.S. Nuclear Regulatory Comission -

101 Marietta Street, NW, Suite 2900 l

J. Michael McGarry, III, Esq.

Atlanta, Georgia 30323 Bishop, Cook, Purcell and Reynolds q

1400 L Street, N.W.

Ms. Karen E. Long a

Washington, D. C.

20005 Assistant-Attorney General q

N. C. Department of Justice Senior' Resident Inspector P.O. Box 629 c/o U.S. Nuclear Regulatory Comission Raleigh, North Carolina :27602 Route 4, Box 529 Hunterville, North Carolina 28078 I

Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W., Suite 2900 Atlanta, Georgia 30323 q

1 Ms. S. S. Kilborn 1

L Area Manager, Mid-South Area ESSD Projects Westinghouse Electric Corporation MNC West Tower - Bay 239 P. 0. Box 355-Pittsburgh, Pennsylvania 15230

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