W3P87-1727, Application for Amend to License NPF-38,clarifying License Condition 2.C.14 Re Fuel Movement in Fuel Handling Building. Fee Paid

Application for Amend to License NPF-38,clarifying License Condition 2.C.14 Re Fuel Movement in Fuel Handling Building. Fee Paid

ML20236C421
Person / Time
Site:	Waterford
Issue date:	07/24/1987
From:	Dewease J LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20236C423	List: ML20236C428 W3P87-1727, Application for Amend to License NPF-38,clarifying License Condition 2.C.14 Re Fuel Movement in Fuel Handling Building. Fee Paid
References
W3P87-1727, NUDOCS 8707300057
Download: ML20236C421 (8)

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.O LOUISIANA 317 BARONNE STREET . P. O. BOX 60340 POWER & LIGHT / NEW ORLEANS, LOUl51ANA 70160 . (504) 595-2781

$lW$S SYS J.G. DEWE ASE July 24, 1987 momt msom NUGEAR OPERATDN$

W3P87-1727 A4.05 QA U.S. Nuclear Regulatory Commission .

ATTN: Document Control Desk Washington, D.C. 20555

Subject:

Waterford SES Unit 3 Docket No. 50-382 License Change Request NPF-38-61 Gentlemen:

Louisiana Power & Light hereby files an application for an amendment to the Waterford 3 Operating License. The amendment involves clarification of License Condition 2.C.14 as it pertains to fuel movement in the Fuel Handling Building.

Fuel receipt for Cycle 3 is tentatively scheduled for mid-February, 1988.

In order to support this schedule and provide sufficient time for procedure changes and other needed preparation, we request that the NRC provide a timely review and Federal Register publication with a goal of issuing an SER prior to the end of this year.

The proposed change does not involve an unreviewed safety question nor a significant hazards consideration. Should you have any question or require additional information, please contact Mike Meisner at (504) 595-2832.

Your very truly, P\

wetse WAAR__ f 8707300057 B70724 . .

I PDR ADOCK 05000302 >nior Vice President -

PDR P Nuclear Operations g JGD:MJM:ssf 7

Enclosure:

NPF-38-61 k *Il Filing fee, LP&L check - $150.00 l cc: R.D. Martin, J.A. Calvo, J.H. Wilson, NRC Resident Inspectors Office, E.L. Blake, W.M. Stevenson, Administrator Nuclear Energy Division l (State of Louisiana), American Nuclear Insurers

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"AN EGUAL OPPORTUNITY EMPLOYER"

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-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION K <

, . In.the matter of )

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Louisiana Power,&.L'ight' Company. )-Docket No. 50-382

Waterford 3 Steam Electric Station .)

AFFIDAVIT J.G. Dewease, being' duly sworn, hereby deposes-and says that he is Senior g Vice President-Nuclear Operations of Louisiana Power & Light Company; that  ;

he'.is duly authorized to sign and file with the Nuclear Regulatory. ,

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. Commission the attached License Change Request; that he is familiar with the content.thereof; and that the matters set forth therein are.true and correctJto the best of his knowledge, information and belief.

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J/(Y!Hevbase .!

ge'nior Vice President-Nuclear Operations -

? i STATE OF LOUISIANA).

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PARISH OF ORLEANSL) 4 1

Subscribed and sworn to before me a Notary Publ n a d for the Parish and State above named ~this cfMI/o day of ,

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ary Public' 1

My Commission expires ,

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. DESCRIPTION AND SAFETY ANALYSIS ~.

OF PROPOSED CHANGE NPF-38-61 1

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& Thisfis_ agrequest to revise License ondition 2.C.14, Spent Fuel Storage

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Ex'isting License Condition See Attachment! A

>- -Proposed ~ License Condition 'l See Attachment B Description.

License Condition 2.C.14 requires testing to confirm the presence of Boraflex in the spent fuel storage racks and places limitations on fuel

.~ assembly locations in the fuel handling building (FHB). The proposed i change will elimina'et the Boraflex testing requirement and expand the i approved fuel assembly locations in the FHB.

The requirement.to confirm the presence of Boraflex in the spent fuel storage racks was'a one-time-only requirement to be completed prior to startup following the.first refueling outage for Waterford 3. The confirmatory. testing was conducted during March,-1985 and the-results were provided to the NRC via W3P86-1495, dated June 6,.1986. By letter dated-

June 23, 1986 the-NRC indicated that the Boraflex testing requirements had j been satisfactorily completed in compliance with'the License Condition.

The proposed change, therefore, deletes the portion of the License Condition associated with Boraflex testing and retitles the License R Condition, consistent'with.its new purpose.

With regard to fuel assembly movement, License Condition 2.C.14 states:  ;

No more than one fuel-assembly shall.be outside an approved shipping container, storage rack or fuel transfer tube in the fuel handling building at any time.

This portion of the License Condition was intended to support the exemption

'to 10CFR70.24 granted to Waterford 3 which, absent the exemption, would have required criticality monitors in the FHB, By placing restrictions on the location of fuel assemblies and'the number of fuel assemblies that may be moved at any one time, the License Condition effectively minimizes the i

potential'for two or more assemblies to come to rest, outside of analyzed locations, sufficiently close to each other to raise criticality concerns.

The proposed change will revise the License Condition to take credit for additional approved fuel assembly locations and clarify the applicability of the License Condition during refueling operations, while continuing to minimize the potential for a critical configuration.

a Refueling Operations During refueling, spent fuel is transferred from the reactor containment building (RCB) to the FHB through the fuel transfer tube. Referring to the figure in Attachment C, the spent fuel handling machine (SFHM) receives the spent fuel from the upender at the north end of the fuel transfer tube.

The spent fuel is then carried by the SFHM through the refueling transfer canal and'the spent fuel cask storage area to its location in the spent fuel pool. Fresh fuel, stored in the spent fuel pool, follows the opposite path to the fuel transfer machine upender for transport to the RCB.

Although not the present practice, fresh fuel may be stored in the new fuel vault. In this case, refueling would involve the FHB crane lif ting an assembly from the new fuel vault and placing it in the fuel elevator at the north end of the refueling transfer canal, to be picked up by the SFHM and transferred to the upender.

Technical Specification 3.9.1, Refueling Operations - Boron Concentration, requires that the reactor coolant system and refueling canal (and, therefore, the spent fuel pool and connected water areas) be borated sufficiently to ensure K e 0.95 or a boron concentration a 1720 ppm, whicheveristhemoreresbictivereactivitycondition. Fuel assembly movements during refueling are carried out entirely underwater in water systems covered by Technical Specification 3.9.1, with the exception of transferring fresh. fuel from the new fuel vault to the fuel' elevator. The boration requirements of Technical Specification 3.9.1, therefore,-ensure that no criticality concerns will arise during underwater operations in refueling.

In the same vein, it is not within the scope of 10CFR70.24 to provide criticality monitoring of underwatet fuel movement. Section 70.24(a) notes, in part, that "[tlhis section is not intended to require underwater monitoring when~special nuclear material is handled or stored beneath water shielding...".

Similarly, the potential for criticality during the movement of fresh fuel from the new fuel vault to the fuel elevator is negligible. In order to approach a critical configuration, two or more fresh fuel assemblies must be removed from the new fuel vault, placed in close proximity to each other and be submerged under unborated water. The only available location to place fresh fuel assemblies in close proximity in the-FHB is the deck area surrounding the water pools. Although such an occurrence is highly improbable, an unborated water source is still necessary for criticality.

In the FHB, unborated water is available from four sources - three 1 inch fire hose lines and one 1 inch eyewash supply line. The FHB deck consists of a number of hatch covers, none of which are water-tight, over an open area below. The vertical distance from the floor below to the FHB deck is )

approximately 81 feet. A water source with a flow rate and capacity clearly in excess of that available in the FHB would be necessary to raise the FHB water 1cvel above the FHB deck. As a result, a critical  ;

configuration due to removing fresh fuel from the new fuel vault during l refueling is not a credible event.

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Based on the above, sufficient means exist to safeguard against critical configurations in the FHB during refueling. Additional limitations on fuel movement, in the form of a License Condition, do not provide tadditional criticality protection nor will the lack of such additional limitations invalidate the existing exemption to 10CFR70.24~during-refueling.

1 Non-Refueling Operations Fuel movement in the FHB outside of Mode 6 largely involves the storage of fresh fuel during new fuel receipt. During new fuel receipt (refor to Attachment C), the hatch covers in the north central portion of the FHB deck are removed. The FHB crane is used to lift the fuel assembi'/ shipping container.from the truck bed below, through the hatch area. The shipping containers are placed on the FHB deck either to the west (preferred) or east of the hatch. In these areas the fuel assemblies are inspected and transferred, by the FHB crane, to the fuel elevator at the north end of the refueling transfer canal. The SFHM retrieves the assembly from the fuel elevator and, passing through the refueling transfer canal and the spent  !

fuel cask storage area, places the new fuel assembly in the spent fuel storage racks. In the future, the new fuel assemblies'may be transferred to the new fuel vault by the FHB crane, however, the present practice is to store new fuel in the spent fuel storage pool due to the number of new assemblies required each reload.

Outside of Mode 6, Technical Specification 3.9.1 does not require boration of the spent fuel storage pool. Although it is Waterford 3's practice to continue to meet the same boration levels in Modes 1-5, with weekly

-surveillance, the following discussion does not credit that boration.

In order to preserve the exemption to 10CFR70.24, while providing additional operational flexibility, the proposed change to License Condition 2.C.14 places physical restrictions on the location of fuel assemblies. .These restrictions provide the same level of protsetion j against a critical configuration as is provided under the existing License Condition.

The proposed change designates certain locations / equipment as acceptable l for residence of a fuel assembly, including an approved shipping container, an approved storage rack, the fuel transfer tube (including upender), the {

fuel' elevator and the SFHM. In addition, a single fuel assembly is allowed  ;

outside of these locations / equipment. (In practice, the single fuel assembly will, most often, be suspended from the FHB crane while in transit to a new location.) q b i Of the approved locations / equipment, all are fixed and widely separated with the exception of the SFHM. It is clear that no critical configuration could occur due to assemblies at the fixed locations.

1 In order to maintain the safety margin to criticality which exists under l the present License Condition, it is only necessary to examine the locations where the fuel assembly transport equipment (FHB crane and SFHM) could place assemblies in close proximity to those assemblies in approved locations. From this viewpoint, two locations of concern can be identified: 1) the north end of the refueling transfer canal where thc L -

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FHB crane an'd SFHM (both carrying a fuel assembly) could converge on the i fuel elevator which could also contain a fuel assembly, and 2) the spent I fuel storage pool where the FHB crane, carrying a fuel assembly from the east new fuel laydown area, could approach the SFHM, also carrying an assembly, in the spent fuel pool. In both cases, it would be necessary to i postulate the drop of at least one fuel assembly to approach a critical config'tration.

For the'first case, at the fuel' elevator, the combination of a mechanical restriction on the lifting height of the FHB crane and a criticality analysis ensure that no critical configuration may occur. In order to approach a critical configuration of two fuel assemblies carried by the FHB crane and SFHM, it is necessary for the FHB crane to drop an assembly from directly above the SFHM in such a way as to strike and dislodge the l assembly carried by the SFHM. Both assemblies must then come to rest in length-wise contact. The FHB crane hook maximum high point .however, is such that, when carrying a fuel assembly, the lower end of the fuel assembly is only approximately three feet above the FHB deck. This is not sufficient height to clear the bridge of the SFHM. The FHB crane, therefore, could not maneuver a fuel assembly directiv over the SFHM. With this physical restriction .however, the FHB crane e- SFHM may still approach the fuel transfer canal with an assembly while an assembly rests in the fuel elevator. For this case, Waterford 3 has performed a criticality analysis postulating that the assembly in transit drops in such a way as to rest vertically at the closest point of approach to the assembly in the fuel elevator. This analysis is similar to those conducted for other assembly drops as discussed in the FSAR. -Due to the cage structure around the fuel elevator assembly and the associated angle iron offsets, the limiting configuration of the two assemblies results in a K

• ff no greater than 0.95.

l For the second case of concern - the approach of the FHB crane and the SFHM in the vicinity of the spent fuel pool - the same physical restriction as in the first case would prevent the FHB crane from lifting an assembly sufficiently high to clear the brioge of the SFHM. Additional restrictions also apply in this case. Presently, a railing runs the length of the spent fuel pool northern edge except for a step off pad where personnel access is administrative 1y controlled. As with the SFHM bridge, the FHB crane is not capable of clearing the railing while carrying a fuel assembly. In addition, the current practice of Waterford 3 is to store spent fuel in the rack locations along the northern portion of the spent fuel pool, and to store new fuel in the racks along the southern edge. When the SFHM is carrying a fuel assembly in the northern half of the spent fuel pool (i.e.

closer to the FHB crane path) it is likely to be a spent fuel assembly to be placed in the racks during refueling, and thus the spent fuel pool is subject to the boration requirements of Technical Specification 3.9.1.

Outside of Mode 6, the SFHM will be moving new fuel into the south end of the spent fuel pool, i.e. widely separated from the FHB crane.

Finally, for both cases, it is the practice of Waterford 3 to assign at least one person to walk with new fuel assemblies as they are being transported by the FHB crane from their laydown/ inspection area to the fuel elevator. In the unlikely case that the FHB crane operator should approach either the SFHM or the northern edge of the spent fuel pool, the individual accompanying the fuel assembly will provide adequate warning to the crane operator.

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During non-refueling operations, therefore, the proposed License Condition will provide the same level of protection against criticality events as the j existing License condition, while affording Waterford 3 increased )

flexibility in fuel movement. In addition, the proposed License Condition j will preserve the assumptions underlying the exemption to 10CFR70.24. l l

Fuel Inspection / Reconstitution l To this point, Waterford 3 has not conducted spent fuel inspection or ,

reconstitution. It is anticipated that any needed inspection /

reconstitution activities would be largely conducted at approved storage rack locations. However, based on industry experience, it may be necessary to utilize temporary inspection / reconstitution locations and equipment.

The proposed License Condition addresses this possibility by ensuring that tue inspection / reconstitution area is borated to at least 1720 ppm, equivalent to the criticality protection afforded during Mode 6.

Safety Analysis The' proposed change described above shall be deemed to involve a  !

significant hazards consideration if there is a positive finding in any of i the following areas:

1. Will operction of the facility in accordance with this proposed change  ;

involve a significant increase in the probability or consequences of 1 any accident previously evaluated?

Response: No As discussed above, the proposed change will maintain the same level of protection against criticality events as that afforded under the existing License Condition. For refueling or inspection /

reconstitution operations, this protection is ensured through the boration requirements of Technical Specification 3.9.1 or its equivalent. During non-refueling operations separation of approved j locations combined with physical restrictions on fuel movement and  !

analysis results ensure that fuel assemblies may not be placed in a critical configuration. Therefore, the proposed change will not increase the probability or consequences of an accident previously evaluated.

2. Will operation of the facility in accordance with the proposed change create the possibility of a new or different kind of accident than previously evaluated?

Response: No The safety approach taken by the current License Condition and Technical Specification 3.9.1 is to provide sufficient physical and other controls on fuel handling to ensure that a critical ,

configuration cannot occur. The proposed License Condition preserves the same concepts of physical separation and boration while increasing i the number of approved fuel assembly locations. The possibility of a criticality event has, therefore, not been increased by the proposed License Condition nor has the possibility of another unevaluated event been raised.

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3. Will operation of this facility in accordance with this proposed change involve a significant reduction in margin of safety?

Response: No The proposed change maintains the margin of-safety afforded by the existing License Condition by utilizing boration requirements, physical limitations and analysis to ensure that the potential for critical configurations is minimized. Therefore, operation of the facility in accordance with the proposed change will not involve a reduction in the margin of safety.

Safety and Significant Hazards Determination Based upon the above Safety Anal- .s, it is concluded that (1) the proposed change does not constitute a significant hazards consideration as defined by 10CFR50.92; (2) there is a reasonable assurance that the health and safety of the public will not be endangered by the proposed change; and (3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.

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