NL-25-0143, Units 3 and 4, License Amendment Request: Spent Fuel Assemblies Maximum Enrichment
| ML25142A172 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/22/2025 |
| From: | Coleman J Southern Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| NL-25-0143 | |
| Download: ML25142A172 (1) | |
Text
A Southern Nuclear May 22, 2025 Docket Nos.: 52-025 52-026 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Regulatory Affairs Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 3535 Colonnade Parkway Birmingham, AL 35243 Tel. 205.992.5000 NL-25-0143 10 CFR 50.90 License Amendment Request: Spent Fuel Assemblies Maximum Enrichment Ladies and Gentlemen:
Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requests an amendment to the combined licenses (COLs) for Vogtle Electric Generating Plant (VEGP) Unit 3 (License No. NPF-91) and 4 (License No. NPF-92).
The license amendment request (LAR) proposes changes to the COLs Appendix A, Technical Specifications (TS) to include "nominal" to clarify requirements for spent fuel assembly initial enrichment.
The Enclosure provides the description, technical evaluation, regulatory evaluation (including the Significant Hazards Consideration Determination) and environmental considerations for the proposed changes.
As discussed during the presubmittal meeting on April 22, 2025 (ML25114A245), SNC requests approval of the proposed license amendment request by September 18, 2025, to allow time for ordering fuel for the next refueling outage. SNC expects to implement the proposed amendment promptly upon issuance.
This letter contains no regulatory commitments. This letter has been reviewed and determined not to contain security-related information.
In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated State of Georgia official.
U. S. Nuclear Regulatory Commission NL-25-0143 Page 2 If you have any questions, please contact Mr. Ryan Joyce at (205) 992-6468.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on the 22nd day of May 2025.
Respectfully submitted,
~~
Jamie M. Coleman Regulatory Affairs Director
Enclosure:
Evaluation of Proposed Changes cc:
NRC Regional Administrator, Region II NRR Project Manager - Vogtle 3&4 Senior Resident Inspector - Vogtle 3&4 Director, Environmental Protection Division - State of Georgia Document Services RTYPE: VND.LI.L00
ENCLOSURE to NL-25-0143 Evaluation of Proposed Changes License Amendment Request: Spent Fuel Assemblies Maximum Enrichment
- 1.
SUMMARY
DESCRIPTION
- 2.
DETAILED DESCRIPTION 2.1. System Design and Operation 2.2. Current Requirements 2.3. Description of Proposed Changes 2.4. Reason for Proposed Changes
- 3.
TECHNICAL EVALUATION
- 4.
REGULATORY EVALUATION 4.1. Applicable Regulatory Requirements/Criteria 4.2. Precedent 4.3. Significant Hazards Consideration 4.4. Conclusions
- 5.
ENVIRONMENTAL CONSIDERATION Attachments 1. Proposed Technical Specification Changes (Mark-ups)
- 2. Clean Revised Technical Specification Pages
- 3. Associated Technical Specification Bases Changes (for information only)
Enclosure to NL-25-0143 Evaluation of Proposed Changes 1.0
SUMMARY
DESCRIPTION Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Southern Nuclear Operating Company (SNC) is requesting an amendment to the Technical Specifications (TS) for the combined licenses (COLs) for Vogtle Electric Generating Plant (VEGP) Units 3 and 4. This request is to revise the COLs Appendix A TS to include "nominal" to clarify requirements for spent fuel assembly initial enrichment.
2.0 DETAILED DESCRIPTION 2.1 System Design and Operation Spent fuel storage rack design and criticality analysis is addressed in Updated Final Safety Analysis Report (UFSAR) Subsection 9.1.2 with reference to the methodology as provided in APP-GW-GLR-029, AP1000 Spent Fuel Storage Racks Criticality Analysis. This report identifies the various criticality calculations to qualify the racks for uniform storage of spent fuel assemblies with a maximum nominal initial enrichment of 4.95 wt% 235U.
2.2 Current Requirements The spent fuel storage rack design and criticality considerations are addressed in the Design Features portion of the Technical Specifications, Section 4.0. Section 4.3 is specific to fuel storage and Section 4.3.1 addresses criticality of the fuel assemblies stored in the spent fuel storage racks. TS 4.3.1.1 requires:
The spent fuel storage racks are designed and shall be maintained with:
- a.
Fuel assemblies having a maximum U-235 enrichment of 4.95 weight percent;
- g.
Partially spent fuel assemblies meeting the initial enrichment and burnup requirements of LCO 3. 7. 12, "Spent Fuel Pool Storage," may be stored in Region 2 of Figure 4.3-1; Storage in Region 2 of the spent fuel storage racks is further addressed in Limiting Condition for Operation (LCO) 3.7.12:
The combination of initial enrichment and burnup of each fuel assembly stored in Region 2 shall be within the limits specified in Figure 3. 7. 12-1.
The initial enrichment is also addressed in SR 3.7.12.1 and in the referenced Figure 3.7.12-1.
2.3 Description of Proposed Change The proposed change to the COL Appendix A would revise TS 4.3.1.1.a and TS 4.3.1.1.g to add "nominal" to clarify the maximum nominal enrichment of 4.95 wt% U-235. Additional changes E-2
Enclosure to NL-25-0143 Evaluation of Proposed Changes are proposed to TS 3. 7.12 and Figure 3. 7.12-1 to clarify that the initial enrichment is initial "nominal" enrichment.
Associated proposed TS Bases changes for TS 3. 7.12 are provided in Attachment 3 for your information only and are consistent with the proposed TS changes.
2.4 Reason for Proposed Change While the analyses for the spent fuel pool criticality evaluation allows for a maximum nominal enrichment of 4.95 wt% with an increased fuel manufacturing tolerance, a conservative reading of the current TS language would limit fuel design to a maximum of only 4.95 wt% U-235 inclusive of tolerance. The current TS do not clearly consider the allowance for manufacturing tolerance; leaving a literal reading of the "maximum" enrichment limited to 4.95 wt% U-235. The proposed change would clarify the TS language to be consistent with the criticality analysis language and use of a manufacturing tolerance.
3.0 TECHNICAL EVALUATION
The criticality analysis (APP-GW-GLR-029) noted in UFSAR 9.1.2 and in TS 3.7.12 Bases already considers fuel tolerances when evaluating spent fuel assemblies with a maximum nominal initial enrichment of 4.95 wt% 235U. Thus, there are no new analyses necessary to support this request.
Specifically, the Spent Fuel Storage Racks Criticality Analysis (APP-GW-GLR-029), Section 7 states, "Unless otherwise stated, all calculations assumed nominal characteristics for the fuel...,"
and Sections 7.1 and 7.2 of APP-GW-GLR-029 identify consideration of "a maximum nominal initial enrichment of 4.95 wt% 235U" and fuel tolerances that allow for "Increased Fuel Enrichment." Table 5.1, Fuel Assembly Specification, combines these to identify a maximum enrichment. Thus, the allowed maximum nominal enrichment is the current TS value of 4.95 wt% U-235, and any instances where maximum enrichment is cited with 4.95% but not clarified with "nominal" are editorial oversight intended to be consistent with all other cited 4.95%
maximum nominal enrichments.
The maximum nominal enrichment is designated as the highest allowable enrichment which can be targeted for fabrication. While there will be some manufacturing variation which could cause individual assemblies to have average enrichments greater than 4.95 weight percent, the AP1000 Spent Fuel Criticality Analysis evaluates an increased fuel manufacturing tolerance in the calculation of Keff to account for these variations.
Such a maximum nominal enrichment is within the regulation limits identified in 10 CFR 50.68, Criticality accident requirements, which include as paragraph (b)(7), "The maximum nominal U-235 enrichment of the fresh fuel assemblies is limited to five (5.0) percent by weight."
The change is also consistent with the Farley Nuclear Plant Units 1 and 2 TS 4.3.1.1.a which identifies the fuel assemblies for the spent fuel storage racks as having a maximum nominal U-235 enrichment of 5.0 weight percent, the language in the above referenced 10 CFR 50.68, and with the language in several other Westinghouse operating plant TS.
In summary, the request is consistent with the spent fuel rack criticality analysis, several other Westinghouse plants, and the presentation of the regulatory limits.
E-3
Enclosure to NL-25-0143 Evaluation of Proposed Changes
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria The following NRC requirements and guidance documents are applicable to the proposed change.
10 CFR 50, Appendix A, General Design Criterion (GDC) 62, Prevention of criticality in fuel storage and handling, states: Criticality in the fuel storage and handling system shall be prevented by physical systems or processes, preferably by use of geometrically safe configurations.
10 CFR 50.68, Criticality accident requirements, states (in part): The maximum nominal U-235 enrichment of the fresh fuel assemblies is limited to five (5.0) percent by weight.
The proposed change does not alter the design of the plants. As a result, the applicability of, and compliance with, the General Design Criterion 62 and 10 CFR 50.68 are not affected.
10 CFR 50.36 "Technical Specifications," states that Technical Specifications shall be derived from the analyses and evaluation included in the safety analysis report. 10 CFR 50.36(C)( 4) states that design features to be included are those features of the facility such as materials of construction and geometric arrangements, which, if altered or modified, would have a significant effect on safety and are not covered in categories described in paragraphs (c) (1 ), (2), and (3) of this section. Therefore, the proposed change is consistent with the requirements of 10 CFR 50.36.
In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
4.2 Precedent None identified. However, the existing TS for Farley Units 1 and 2 and several other Westinghouse plants have similar TS language, i.e., with "nominal" terminology.
4.3 Significant Hazards Evaluation Southern Nuclear Operating Company (SNC) is requesting an amendment to the Technical Specifications (TS) to include "nominal" to clarify requirements for spent fuel assembly enrichment.
SNC has evaluated the proposed changes to the TS using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration, as discussed below.
- 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
E-4
Enclosure to NL-25-0143 Evaluation of Proposed Changes Response: No The proposed change clarifies the spent fuel rack fuel assemblies' enrichment values are "nominal," to be consistent with the existing safety analysis. Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed change clarifies the spent fuel rack fuel assemblies' enrichment values are "nominal," to be consistent with the existing safety analysis. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No The proposed change clarifies the spent fuel rack fuel assemblies' enrichment values are "nominal," to be consistent with the existing safety analysis. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
Based upon the reasoning presented above, SNC concludes that the requested change involves no significant hazards consideration, as set forth in 10 CFR 50.92(c), "Issuance of Amendment."
4.4 Conclusions In conclusion, based on considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or the health and safety of the public.
5.0 ENVIRONMENTAL CONSIDERATION The amendment changes requirements with respect to the format of the license or otherwise makes editorial, corrective, or other minor changes. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(1 0)(v). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.
E-5
ATTACHMENT 1 to NL-25-0143 Proposed Technical Specification Change (Mark-ups)
License Amendment Request: Spent Fuel Assemblies Maximum Enrichment (This enclosure consists of 4 pages, including this cover page)
Technical Specifications Spent Fuel Pool Storage 3.7.12
- 3. 7 PLANT SYSTEMS 3.7.12 Spent Fuel Pool Storage LCO 3.7.12 The combination of initial nominal enrichment and burnup of each fuel assembly stored in Region 2 shall be within the limits specified in Figure 3.7.12-1.
APPLICABILITY:
Whenever any fuel assembly is stored in Region 2 of the spent fuel pool.
ACTIONS
- NOTE -
LCO 3.0.3 is not applicable.
CONDITION REQUIRED ACTION COMPLETION TIME A.
Requirements of the LCO not met.
A.1 Initiate action to move the Immediately noncomplying fuel assembly to an acceptable storage location.
SURVEILLANCE REQUIREMENTS SR 3.7.12.1 SURVEILLANCE Verify by administrative means the initial nominal enrichment and burnup of the fuel assembly is in accordance with Figure 3.7.12-1.
FREQUENCY Prior to storing the fuel assembly in Region 2 VEGP Units 3 and 4 3.7.12-1 Amendment No._
~ (Unit 3)
Amendment No._
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45 40 35 S-30 1-
- E a 25
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Q. 20
- a.
- J C: :; 15 co 10 5
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2 Technical Specifications Region 2 Loading Curve Acceptable Region I
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V
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Spent Fuel Pool Storage 3.7.12
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/ v I Unacceptable Region I 2.5 3
Nominal 3.5 Enrichment (wt3/4 U-235)
Figure 3.7.12-1 4
Minimum Fuel Assembly Burnup Versus 4.5 5
Initial Nominal Enrichment for Region 2 Spent Fuel Cells VEGP Units 3 and 4 3.7.12-2 Amendment No._
~ (Unit 3)
Amendment No._
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Technical Specifications Design Features 4.0 4.0 DESIGN FEATURES 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:
- a.
Fuel assemblies having a maximum nominal U-235 enrichment of 4.95 weight percent;
- b.
kett::; 0.95 if flooded with unborated water which includes an allowance for uncertainties (Region 1 racks);
- c.
A nominal 10.93 inch center-to-center distance between fuel assemblies placed in Region 1 of the spent fuel storage racks;
- d.
A nominal 9.04 inch center-to-center distance between fuel assemblies placed in Region 2 of the spent fuel storage racks;
- e.
A nominal 11.65 inch center-to-center distance between fuel assemblies placed in the Defective Fuel Cells;
- f.
New or partially spent fuel assemblies with any discharge burnup may be allowed unrestricted storage in Region 1 and the Defective Fuel Cells of Figure 4.3-1;
- g.
Partially spent fuel assemblies meeting the initial nominal enrichment and burnup requirements of LCO 3.7.12, "Spent Fuel Pool Storage,"
may be stored in Region 2 of Figure 4.3-1; and
- h.
kett < 1.0 if flooded with unborated water and kett::; 0.95 if flooded with borated water at a minimum soluble boron concentration described in the Bases for LCO 3. 7.12 for normal and design basis criticality-related accident conditions, which includes an allowance for uncertainties (Region 2 racks).
4.3.1.2 The new fuel storage racks are designed and shall be maintained with:
VEGP Units 3 and 4
- a.
Fuel assemblies having a maximum U-235 enrichment of 5.0 weight percent;
- b.
The maximum kett value, including all biases and uncertainties, shall be less than or equal to 0.95 with full density unborated water; 4.0 - 2 Amendment No._
~ (Unit 3)
Amendment No._
~ (Unit 4)
ATTACHMENT 2 to NL-25-0143 Clean Revised Technical Specification Pages License Amendment Request: Spent Fuel Assemblies Maximum Enrichment (This enclosure consists of 4 pages, including this cover page)
Technical Specifications Spent Fuel Pool Storage 3.7.12
- 3. 7 PLANT SYSTEMS 3.7.12 Spent Fuel Pool Storage LCO 3.7.12 The combination of initial nominal enrichment and burnup of each fuel assembly stored in Region 2 shall be within the limits specified in Figure 3.7.12-1.
APPLICABILITY:
Whenever any fuel assembly is stored in Region 2 of the spent fuel pool.
ACTIONS
- NOTE -
LCO 3.0.3 is not applicable.
CONDITION REQUIRED ACTION COMPLETION TIME A.
Requirements of the LCO not met.
A.1 Initiate action to move the Immediately noncomplying fuel assembly to an acceptable storage location.
SURVEILLANCE REQUIREMENTS SR 3.7.12.1 SURVEILLANCE Verify by administrative means the initial nominal enrichment and burnup of the fuel assembly is in accordance with Figure 3.7.12-1.
FREQUENCY Prior to storing the fuel assembly in Region 2 VEGP Units 3 and 4 3.7.12-1 Amendment No. TBD (Unit 3)
Amendment No. TBD (Unit 4)
45 40 35 I
s-30 I-
~ 25 i
Q.
- a. 20
- I C:... 15
- I CD 10 5 /
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Technical Specifications Reg ion 2 Loading Curve Acceptable Reg ion I
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V
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Spent Fuel Pool Storage 3.7.12
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I Unacceptable Region I
2.5 3
3.5 4
4.5 5
Nominal Enrichment (wt% U-235)
Figure 3.7.12-1 Minimum Fuel Assembly Burnup Versus Initial Nominal Enrichment for Region 2 Spent Fuel Cells VEGP Units 3 and 4 3.7.12-2 Amendment No. TBD (Unit 3)
Amendment No. TBD (Unit 4)
Technical Specifications Design Features 4.0 4.0 DESIGN FEATURES 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:
- a.
Fuel assemblies having a maximum nominal U-235 enrichment of 4.95 weight percent;
- b.
kett::; 0.95 if flooded with unborated water which includes an allowance for uncertainties (Region 1 racks);
- c.
A nominal 10.93 inch center-to-center distance between fuel assemblies placed in Region 1 of the spent fuel storage racks;
- d.
A nominal 9.04 inch center-to-center distance between fuel assemblies placed in Region 2 of the spent fuel storage racks;
- e.
A nominal 11.65 inch center-to-center distance between fuel assemblies placed in the Defective Fuel Cells;
- f.
New or partially spent fuel assemblies with any discharge burnup may be allowed unrestricted storage in Region 1 and the Defective Fuel Cells of Figure 4.3-1;
- g.
Partially spent fuel assemblies meeting the initial nominal enrichment and burnup requirements of LCO 3.7.12, "Spent Fuel Pool Storage,"
may be stored in Region 2 of Figure 4.3-1; and
- h.
kett < 1.0 if flooded with unborated water and kett::; 0.95 if flooded with borated water at a minimum soluble boron concentration described in the Bases for LCO 3. 7.12 for normal and design basis criticality-related accident conditions, which includes an allowance for uncertainties (Region 2 racks).
4.3.1.2 The new fuel storage racks are designed and shall be maintained with:
VEGP Units 3 and 4
- a.
Fuel assemblies having a maximum U-235 enrichment of 5.0 weight percent;
- b.
The maximum kett value, including all biases and uncertainties, shall be less than or equal to 0.95 with full density unborated water; 4.0 - 2 Amendment No. TBD (Unit 3)
Amendment No. TBD (Unit 4)
ATTACHMENT 3 to NL-25-0143 Associated Technical Specification Bases Changes
{For information only)
License Amendment Request: Spent Fuel Assemblies Maximum Enrichment (This enclosure consists of 4 pages, including this cover page)
Technical Specifications Bases Spent Fuel Pool Storage B3.7.12 B 3. 7 PLANT SYSTEMS B 3.7.12 Spent Fuel Pool Storage BASES BACKGROUND VEGP Units 3 and 4 The high density spent fuel storage racks are divided into two separate and distinct regions and include locations for storage of defective fuel as shown in Figure 4.3-1. Region 1, with a maximum of 243 storage locations and the Defective Fuel Cells, with 5 storage locations.,_ are designed and analyzed (Ref. 2) to accommodate new fuel assemblies with a maximum nominal enrichment of 4.95 weight percent U-235, or spent fuel assemblies regardless of the combination of initial nominal enrichment and burnup. Region 2, with a maximum of 641 storage locations is designed and analyzed (Ref. 2) to accommodate spent fuel assemblies in all locations which comply with the combination of initial nominal enrichment and burnup specified in LCO Figure 3.7.12-1, Minimum Fuel Assembly Burnup Versus Initial Nominal Enrichment for Region 2 Spent Fuel Cells. To allow for burnup uncertainty, which the Region 2 loading curve of LCO Figure 3.7.12-1 does not include, the fuel assembly burnup from the reactor records shall be conservatively reduced.
The water in the spent fuel pool normally contains soluble boron, which would result in large subcriticality margins under actual operating conditions. For storage of fuel in the spent fuel racks, the design basis for preventing criticality outside the reactor is that there is a 95% probability at a 95% confidence level, without soluble boron, that the effective multiplication faction (keff) of the fuel assembly array will be less than 0.997, including uncertainties and tolerances. The NRC guidelines specify a keff limit of< 1.0 for normal storage in the absence of soluble boron. Hence, the design is based on the use of unborated water, which maintains a subcritical condition for the allowed loading patterns.
The double contingency principle discussed in ANSI N-16.1-1975 and the April 1978 NRC letter (Ref. 1) allows credit for soluble boron under other abnormal and accident conditions, since only a single independent accident need be considered at one time. For example, the only accident scenario that has the potential for more than negligible positive reactivity effect is an inadvertent mislocating of a new fuel assembly. This accident has the potential for exceeding the limiting reactivity, should there be a concurrent and independent accident condition resulting in the loss of all soluble poison. To mitigate these postulated criticality related accidents, boron is dissolved in the pool water. Safe operation with unborated water and no movement of assemblies may, therefore, be achieved by controlling the combination of initial enrichment and burnup in accordance with the accompanying LCO. Prior to movement of an assembly, it is necessary to perform SR 3.7.12.1.
B 3.7.12 - 1 Revision
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BASES APPLICABLE SAFETY ANALYSES LCO APPLICABILITY ACTIONS VEGP Units 3 and 4 Technical Specifications Bases Spent Fuel Pool Storage B3.7.12 The fuel handling accident can only take place during or as a result of the movement of an assembly (Refs. 2 and 3). For these accident occurrences, the presence of soluble boron in the spent fuel pool (controlled by LCO 3.7.11, "Spent Fuel Pool Boron Concentration")
prevents criticality. By closely controlling the movement of each assembly and by checking the location of each assembly after movement, the time period for potential accidents may be limited to a small fraction of the total operating time. During the remaining time period with no potential for accidents, the operation may be under the auspices of the accompanying LCO.
The configuration of fuel assemblies in the spent fuel pool satisfies Criterion 2 of 1 O CFR 50.36(c)(2)(ii).
The restrictions on the placement of fuel assemblies within Region 2 of the spent fuel pool in the accompanying LCO, ensure the kett of the spent fuel pool will always remain< 0.997, assuming the pool to be flooded with unborated water and ::; 0.95, with a boron concentration of greater than or equal to 800 ppm.
Region 2 permits storage of spent fuel assemblies in any cell location provided the assembly meets the combination of initial nominal enrichment and burnup shown in LCO Figure 3.7.12-1, Minimum Fuel Assembly Burnup Versus Initial Nominal Enrichment for Region 2 Spent Fuel Cells. The Acceptable Region of the Figure is to the left and above the curve.
This LCO applies whenever any fuel assembly is stored in Region 2 of this spent fuel pool.
LCO 3.0.3 is applicable while in MODE 1, 2, 3, or 4. Since spent fuel pool storage requirements apply in all MODES when fuel is stored in Region 2, the ACTIONS have been modified by a Note stating the LCO 3.0.3 is not applicable. Spent fuel pool storage requirements are independent of reactor operations. Entering LCO 3.0.3 while in MODE 1, 2, 3, or 4 would require the unit to be shutdown unnecessarily.
B 3.7.12 - 2 Revision
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Technical Specifications Bases BASES Spent Fuel Pool Storage B3.7.12 ACTIONS (continued)
A.1 SURVEILLANCE REQUIREMENTS REFERENCES VEGP Units 3 and 4 The LCO is not met if spent fuel assemblies stored in Region 2 spent fuel assembly storage locations do not meet the applicable initial nominal enrichment and burnup limits in accordance with Figure 3.7.12-1.
When the LCO is not met, action must be initiated immediately to make the necessary fuel assembly movement(s) in Region 2 to bring the storage configuration into compliance with Figure 3.7.12-1 by moving the affected fuel assemblies to Region 1 or the Defective Fuel Cells.
SR 3.7.12.1 This SR verifies by administrative means that the initial nominal enrichment and burnup of the fuel assembly is in accordance with Figure 3.7.12-1. Fuel assemblies stored in Region 2 that do not meet the Figure 3.7.12-1 enrichment and burnup limits shall be stored in Region 1
- or Defective Fuel Cells.
- 1.
Double contingency principle 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).
- 2.
APP-GW-GLR-029, "AP1000 Spent Fuel Storage Racks Criticality Analysis," Westinghouse Electric Company LLC (Westinghouse Proprietary).
- 3.
FSAR Sections 9.1.2, "Spent Fuel Storage" and 15.7.4, "Fuel Handling Accident."
B 3.7.12 - 3 Revision
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