ML20247D055
| ML20247D055 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 03/23/1989 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | Swenson W NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20247D057 | List: |
| References | |
| CON-NRC-89-36 VPNPD-89-189, NUDOCS 8903300366 | |
| Download: ML20247D055 (4) | |
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Wiscot1 sin 1Electnc POWER COMPANY 231 W Michigan, PO. Box 2046. Milwaukee, WI 53201 (414)221-2345 VPNPD-89-189 NRC-89 March 23,-1989 U.
S.
Nuclear Regulatory Commission 10CFR50.59 Document Control Desk Mail Station Pl-137 Washington, D.C.
20555 Attention:
Mr. Warren Swenson, Project Manager PNR Project Directorate III-3 Gentlemen:
DOCKET NOS. 50-266 AND 50-301 TECHNICAL SPECIFICATION CHANGE REQUEST NO. 130 NUCLEAR FUEL STORAGE ENRICHMENT POINT BEACH NUCLEAR PLANT UNIT 1 AND 2 In accordance with the requirements of 10CFR 50.59(c) Wisconsin Electric Power Company (Licensee) hereby requests amendments to Facility Operating Licenses DPR-24 and DPR-27 for the Point Beach Nuclear Plant Units 1 and 2, respectively, to incorporate changes in the Technical Specifications regarding permissible enrichments-for storage of fuel assemblies in the new fuel storage vault and spent fuel storage pool.
In the case of this amendment for License DPR-24, we believe that exigent circumstances are present.
We therefore request the NRC invoke the exigency provisions of 10CFR50.91 to permit the issuance of this license amendment to support the Point Beach Unit 1 Refueling No. 16.
Details of the changes requested in this amendment application and an explanation of the exigency are provided herewith.
On July 6, 1988, Licensee submitted a license amendment application and Technical Specification Change Request No. 124.
The purpose of the request was to propose a revision to Technical Specification 15.5.4.2 which would permit storage of OFA fuel assemblies with higher fresh fuel enrichments.
Presently, the specifications permit storage of fuel assemblies with initial enrichments of 39.4 grams of U-235 per axial centimeter of OFA fuel assemblies.
This corresponds to a nominal enrichment of 4.0 weight percent (w/o) U-235.
The July 6, 1988 proposed revision to this specification increases that limit to 46.8 grams of U-235 per axial centimeter of OFA fuel assemblies, or a nominal enrichment of 4.75 w/o U-235.
The July 6, 1988 application included a discussion of the criticality analyses conducted for both the new and spent fuel storage racks.
The analyses demonstrated that storage of OFA fuel at enrichments of 4.75 w/o in both the new fuel storage vault and the spent fuel storage pool provides adequate margin b#
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U.S. NRC. Document Control Desk March 23, 1989 Page 2 to the limiting licensing value for maintaining a 5% shutdown margin (K
0 as stated in specification 15.5.4.2).
This conclusion is alsb su<pp. 9 5, orted by the original criticality analysis for the Point Beach new and spent fuel storage racks for OFA fuel which was provided with our letter to Mr.
H.
K.
Denton dated September 6, 1983.
Our letter also provided an evaluation of the potential effects higher enrichment fuel, in conjunction with increased discharge burnup, would have on spent fuel storage relative to decay heat, radiation effects and gamma heating effects on the spent fuel pool walls.
We concluded that over the long term these parameters are essentially the same as they were at lower burnups because higher discharge burnups result in fewer fuel assemblies being discharged per cycle and that heating and l
gamma dose considerations are bounded by the original OFA analysis in the September 6, 1983 letter referenced previously.
Although our July 6, 1988 letter did not request a specific date for approval of that amendment request, we had anticipated that NRC review would proceed promptly and approval of the application could be expected in early 1989.
In early February, we inquired as to when this license amendment would be issued and were subsequently notified that, because it was necessary for the NRC to engage an outside consultant to perform and verify calculations concerning the possible environmental effects of potential accidents involving high burnup discharged fuel, NRC approval of our July 6, 1988 amendment request would not be possible before the end of 1989.
At that time we notified you that sixteen of the twenty-eight OFA fuel assemblies being fabricated by Westinghouse for the Point Beach Unit 1 spring 1989 refueling were being manufactured with fuel enriched to a nominal 4.0 w/o U-235.
We indicated that it was possible that because of the normal enrichment tolerance of + 0.05 weight percent one or more of these sixteen assemblies might exceed the specification limit of 39.4 grams of U-235 per axial centimeter.
All fuel assemblies for Region 19B have now been fabricated.
We have determined that the axial U-235 loadings of these assemblies vary from a low of 39.19 gm/cm to a high of 39.64 gm/cm.
Although nine of the sixteen assemblies exceed the 39.4 gm/cm specification, the mean axial U-235 fuel loading for Region 19B is 39.415 gm/cm.
On March 20, we provided this information to Messrs Warren Swenson and Tim Collins of your staff with our conclusion that these assemblies satisfied the intent of this specification. On March 21, we were advised by Mr.
Swenson that our interpretation was contrary to that of the NRC staff and that each of the assemblies must comply with the specification 15.5.4.2 limit in order to be stored in either the new fuel or spent fuel storage racks at the Point Beach Nuclear Plant.
Accordingly, we are proceeding with this amendment request.
We have attached a revised Technical Specification page 15.5.4-1 which contains a revised fuel assembly storage specification for OFA fuel assemblies.
The revised limit is 40.0 grams of U-235 per axial i
U. S. NRC Document Control Desk March 23, 1989 Page 3-centimeter'of OFA fuel assembly.
That axial loading l'imit is equivalent to an enrichment of 4.05 w/o U-235'and therefore
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incorporates the normal fuel enrichment tolerance.
In-order to remove the ambiguity in interpretation of this loading. limit, we'have also1 changed the' word " assemblies" to " assembly" for both the standard-and OFA axial loading limits.
We are scheduled to shutdown Point Beach Unit 1 for a six week refueling and maintenance outage on' April 1, 1989.
In order to support the loading of Region 19B into the Unit 1 reactor vessel we would nominally have moved all the Region 19B fuel assemblies into the l
. spent fuel pool before commencing the core refueling.
The Unit 3 core loading and fuel assembly shuffle are scheduled to commence on April 13 and should be completed by April 21..This schedule would permit the refueling to' proceed without impacting the overall critical path-of this-outage.
The schedule for the primary plant-related outage activities, which includes among other things, steam generator testing and inspection, reactor coolant pump motor and seal maintenance, and the fuel shuffle, includes a three-day scheduling contingency to avoid having.these activities become critical path evolutions.for the outage.
Therefore it is possible, assuming all other outage activities are completed on time, that we could delay inserting the Region 19B fuel assemblies into the spent fuel pool until April 15, 1989.
We therefore would request that this license amendment for Point Beach Unit 1 be issued, if possible, by April 12 and no later than April 15, 1989.
Until this change is approved, we will be storing-those Region 19B assemblies which exceed the 39.4 gm/cm axial loading in the shipping containers in which they were received.
We believe this. request constitutes an exigency in that failure to obtain this timely relief from the NRC interpretation of the existing specification could cause a delay in.the resumption of operation of Point Beach Unit 1.
Unless specification 15.5.4.2 is revised as requested herein, we shall be' unable to store those fuel assemblies which exceed 39.4 gm/cm axial loading in the spent fuel pool.
This will result in a significant delay in the sequencing for the core load and fuel shuffle, since each of those assemblies will have to be handled, using extraordinary measures and special procedures, separately and singly from the new fuel shipping containers to the reactor vessel.
Such a delay could extend the refueling outage and delay the return to power by one and one-half days.
If we subsequently had to unload the core, startup could be delayed indefinitely, since we would have no authorized storage area for these fuel assemblies.
We further believe that licensee has and had acted in good faith to avoid this exigency in that application to revise this specification limit was submitted nine months prior to the scheduled shutdown and licensee had no actual knowledge that any Region 19B OFA fuel assemblies would marginally exceed the specification limit until final fabrication of these assemblies was complete.
We further believe that
U.S.
NRC Document Control Desk March 23, 1989 Page 4 licensee's interpretation of the existing specification, i.e.,
that the limit be applied on a regional basis, was reasonable and that we had no prior knowledge of the staff's decision on this specification.
As required by 10CFR50.91(a), we have evaluated this change in accordance with the standards specified in 10CFR50.92 to determine if the proposed change constitutes a significant hazards consideration.
The proposed change should be characterized as an administrative correction to ackowledge a normal manufacturing tolerance in the fuel assembly axial loading limits.
In that light, the NRC safety evaluation provided with license amendments 86 and 90 to Facility Operating Licenses DPR-24 and DPR-27 respectively, and dated October 5,
1984, is a basis for justification for this change request.
Notwithstanding that acknowledgment, we would note further that the no significant hazards consideration evaluation provided with our amendment application of July 6, 1988, is equally and completely applicable to this amendment request.
A higher U-235 enrichment does not affect any accident previously evaluated or cause a new or different kind of accident because that parameter is not considered in accident analyses performed for operations of the Point Beach Nuclear Plant.
The third 10CFR50.91 criteria, that is no significant reduction in the margin of safety, is also satisfactorily demonstrated for enrichments to 4.75 w/o, equivalent to 46.8 gm/cm, in our July 6, 1988 submittal and accordingly is applicable to the 4.05 w/o, or 40.0 gm/cm, requested in this application.
We trust the information we have provided herein will be adequate and sufficient to permit you to conclude a prompt review of this amendment request.
Should you need any additional information or clarification of the information provided, please contact us at once.
If necessary, we are prepared to meet with you at your convenience to facilitate this review.
Very truly yours,
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C.
W.
Fay Vice President Nuclear Power Copy to NRC Regional Administrator, Region III NRC Resident Inspector R. S.
Cullen, PSCW l
Subscribed and sworn to before me this,Nd day of h% v b, 1989.
e m
TV (km Notary Public, State of Wisconsin My Commission expiresjI' 2 7-YO.
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