ML19325E885

Application for Amend to License DPR-72,consisting of Tech Spec Change Request 175,increasing Spent Fuel Pool Storage Capacity & Allowable Fuel Enrichment to 4.2% in Fuel Pool B

ML19325E885
Person / Time
Site:	Crystal River
Issue date:	10/31/1989
From:	Boldt G FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19325E886	List: ML19325E885 ML19325E887 ML19325E888
References
3F1089-28, NUDOCS 8911090315
Download: ML19325E885 (16)

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..e C 0hro n AlloN october 31, 1989 3F1089-28 U.S. Nuclear Regulatory Comission Attuition: Deatment Cortal Desk Washington, D.C. 20555 Subjects crystal River Unit 3 ~

Docket No. 50-302 Operating License No. D6R-72 Technical Specification Change Request No.175 Spent Fuel Pool Storage Capacity Dear Sir Florida Power Corporation (TPC) hereby subnits Technical Specification Charx3e Request No.' (TSCRN) 175, requesting an amendment to Appersiix A of Operating

, License No. DER-72. As part of this request, the proposed Iglacenant pages l for Appendix A and associated haama are provided.

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'Ihis submittal requests an increase in the capacity of the spent fuel storage pool and an increase in the allowable fuel enrichment to 4.2 percent in fuel

, pool B. 'Ihe rerack of storage pool B will support storage of fuel by means of l a two region layout. Region 1 will sqp5crt storage of fresh fuel of 4.2 w/o U-L 235 and Region 2 will support storage of fuel of initial enrichment of 4.2 w/o l with credit for burnqp.

I Region 1 (174 locations) will consist of high density fuel acaembly spacirq obtained by utilizing a neutron absorbing material and will be reserved for oore off Icading. Region 2 (641 locations) will also consist of high density fuel a=::.umely spacing and will provide normal storage for spent fuel I

assenblies.

Darirg the rarack modification spent fuel in pool B will be stored in pool A with the transfer canal gate in place. Missile shields that are normal.ly in place cver the spent fuel pools will remain in place over pool A while the old racks are being removed and the new racks are installed in pool B.

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0911090315 891031 l gDR ADOCK0500p,gg2

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! Post office Box 219

• Crystal River, Floriaa 32629. Telephone (904) 795 3802 ll A Florida Progress Company

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i October 31, 1989 I l 3F1089-28 l t Page 2 t

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! FPC regnests this apprwal of this anendment prior to May 31, 1990 in order to

'- aoocamodate receipt and installation of the new fuel racks after Refuel 7 I (schech11ed to begin Mardt 1990). (

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sincerely,  !

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6 Gary idt, Vios President ,

i Nuclear Production  ;

i GB/GHF/adr (

Attact a nt  ;

i a:: Regional Administrator, Region II i Senior Resident Inspector  !

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I WIND STATES OF AMERICA  ;

NUCIEAR REGUIA'ITRY CGtGSSIN  ;

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i o- IN '!HE MCITR )  ;

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3 ) DO NET NO. 50-302  :

FIIRIDA 3CHER CORIGATIN ) [

(2RTIFICAE OF SERVICE -

Gary Boldt deposes and says that the following has been served on the h Designated State Rsomeentative arx1 Chief hecutive of Citrus County, Florida,  ;

by deposit in the United States mail, addressed as follows: l l

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Chairman, Administrator  !

Board of County ocumissioners Radiological Health Servloes  !

of Citrus County Department of Health and ['

Citrus County ocurthouse Rehabilitative Services Inverness, E 32650 1323 Winewood Blvd. f Tallahassee, E 32301

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A ocpy of Technical Specification (.hange Request No.175, requesting Amer &ent to Appendix A of Operatig Idoensing No. OPR-72.  ;

Fr.cRim IWER CORPNATIW j

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l Gary Boldt, Vice Pmsident  !

Nuclear Production  ;

/ SWORR 'IO AND SUBSCRIBED BE2%RE ME 'IHIS 31st DAY OF OCIOBER,1989. {

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h ry Public l

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Notary Public, State of Floridp at large  !

My Commission hpirest /0 / 9/9 3-  ;

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l STKIE OF FLORIIR

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i Gary Boldt states that he is the Vloe Pmsident, Nuclear Prtduction for Florida Ibwer Corporation; that he is authorized on the part of l i

said ompany to sign and file with the Nuclear Regulatory omnission

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the information attached hereto; and that all such statements made l

and matters set forth therein are true and correct to the best of l his knowledge, infomation, ard belief.

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Gary Bofdt, Vice President <

Nuclear Production  ;

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Subscribed arx1 sworn to before me, a Notary Ibblic in and for the State and County above named, this 31st day of Oct@er, 1989. ,

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4 Mary Public  !;

i Notary Public, State of Florida at large My onmisolon D:pires /0// 9/9 w NOT ARY PUBLIC. STATE OF FLORIDA AT t.ARGE VV COMMIS$lON (KP4:E$ OCT.19,1992 sio%:oi.mous **iom Awe:v ovo

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FLORIDA POWER 00RPORATION CRYSTAL RIVER UNIT 3 j DOCKET NO. so-sc /LIcsNSE NO. DPR-7: l REQUES? NO. 175, REVISION o j

q. 6 SPENT FUEL POOL STORhSE CRPACITY l I

LICENSB DOCUMENT INVOLVED Technical Specifications {

r PORTIONS XIV 3.9.11 l

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3.9.13  :

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4.9.13.4 l

/ Figure 3.9-2 {

5.6.1 j 5.

6.3 DESCRIPTION

OP REQUEST:

i This Technical Specification Change Request la requesting j t

1. 4 one time relief from Technical Specification 3.9.11 to allow ,

removal of the missile shield for installation of high density i spent fuel storage racks in pool B. This one time relief would be in effect for the duration of the spent fuel pool B rarack ,

modification. ,

2. an increase in the allowable nominal fuel enrichment in weignt t percent of U-235 for spent fuel pool B. l i

3. an increase in the number of spent fuel storage locations from l "1153" to "1357" for both pools, and decrease the number of i failed fuel containers from 8 to 0 in pool B.  !

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4. an expansion of Section 5.6.1 to indicate that the high density i spent fuel racks in pool B will utilize a two region layout. i Region 1 will have a 10.60 inch center-to-center spacing and  !

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Region 2 Will have a 9.17 inch center-to-center spacing. I

REASON FOR REQUEST i

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currently spent fuel pool B contains standard geometric reactivity L control racks totaling 120 cells with center-to-centor spacing of  ;

21 1/8 inches. In addition, there are provisions to store eight  !

l failed fuel canisters. Each rack is mechanically fastened to studs ,

L protruding from the pool floor. The proposed modification will 1 increase the storage capacity in the spent fuel pools and will l' consist of replacing existing fuel assembly racks with high density, free standing storage racks without changing the basic  ;

structural geometry of the spent fuel pool.

1. Florida Power Corporation (FPC) request a one time relief from Technical Specification 3.9.11 which requires that all missile

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i shields be maintained over the top of irradiated fuel assemblies seated in the storage racks when ever irradiated fuel assemblies are in the storage pool. This request will allow for installation of the high density spent fuel storage racks in spent fuel pool B (and removal of the present spent fuel racks).

2. Florida Power Corporation will utilize up to 4.2 weight percent enriched fuel during Cycle 9 and possibly subsequent cycles, our current fuel storage analyses and Technical Specifications reflect a maximum 4.0 weight percent enrichment for storage pool B. This change supports an enrichment increase to 4.3%

for storage pool B. (see item #3 below).

3. As a result of the uncertainty concerning the Department of Energy fulfilling its contractual obligations under the Nuclear Waste Policy Act (NWPA), Florida Power Corporation has decided i to pursue the licensing and subsequent installation of high density fuel storage racks at Crystal River Unit 3 (CR-3). We l

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feel that this cours,e of action is required in order to protect our ability to continue to operate CR-3 until resolution of the spent fuel problem is achieved. Based on the current fuel

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storage capacity for pool B, CR-3 will lose full core reserve

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after Refuel 7 in. March 1990. To achieve this goal, Florida Power Corporation has contracted Westinghouse to design,

! fabricate and install the high density fuel storage racks for Crystal River Unit 3.

p 4. Florida Power Corporation will utilize a two region design in spent pool B to differentiate the storage areas between the two types of fuel assemblies and the flexibility to provide l additional fuel assembly storage capacity (using pin l consolidation). Region 1 racks are poison racks designed to store fresh and spent fuel and consolidated arrays of fuel at ,

a maximum ratio of 2:1. Region 2 racks are designed to take i

credit for burnup and to store consolidated arrays of fuel at

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a maximum ratio of 2:1.  ;

EVALUATION OF REQUEST

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1. An evaluation has been performed to determine the consequences of tornado-generated missiles impacting the spent fuel pool ,

while performing fuel rack densification work in pool B. ,

During the rarack modification all spent fuel will be in pool i A, the missile shielding above pool B will be removed, the l transfer canal gate between the pools and the A pool missile snielding will be installed. The evaluation has determined that the missile spectrum utilized in the Crystal River FSAR analyses will not impact the spent fuel stored in this configuration. '

l 2. The purpose of limiting the combination of allowable fuel enrichment and burnup of assemblies stored in storage pool B is to naure sufficient safety margin existo to prevent

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inadvertent criticality. These limits is maintained underassure a K* eq all conditk,ons.ual to or less than 0.95 The attached analysis indicates that storage of fuel up to 4.2 l

< initial weight percent enrichment in storage pool B will not cause K,,, to exceed 0.95. Administrative controls shall be

! used to prevent storage of fuel assemblies having less than an

! acceptable combination of fuel enrichment and burnup, remains less than or the equaldesign of the to 0.95 racks under all is such that K*

conditions, inc' luding fuel handling accidents. The close spacing of the racks precludes insertion 4 of fuel assemblies in other than design storage locations, )

except in an area south of the Region 1 racks where a fuel i assembly may be inserted between the pool wall and the racks.

Such inadvertent insertion of a fuel into this location, or the placement of a fuel assembly across the top of a fuel rack, is considered a postulated accident, and as such, realistic 1 initial conditions such as boron in the water can be taken into  !

account. This condition has an acceptable K,,, of less that I 0.95. l

3. Increasing the capacity of the Crystal River spent fuel pool ,

will not effect the environment nor increase the doses to personnel from radionuclide concentrations in the spent fuel pool area. The effects of additional loads on the existing pool structure due to the high capacity storage racks have been 1 examined. The pool structural integrity is assured by j conformance with the original FSAR acceptance criteria. The i spent fuel racks are seismic Category I equipment. Therefore, j they are required to remain functional during and after an SSE.  !

No significant increase in volume of solid radioactive wastes is expected to be generated.

4. The spent fuel storage racks provide safe subcritical storage '

of fuel assemblies by providing suf ficient center-to-center spacing or a combination of spacing and poison to assure K,,, is  !

equal to or less than 0.95 for normal operations and postulated  :

accidents. The spent fuel racks consist of two designs with varying storage capability. Region 1 consists of high density fuel assembly spacing obtained by utilizing a neutron absorbing material and is reserved for core off loading. Regica 2 also consists of high density fuel assembly spacing and provides normal storage for spent fuel assembles. Region 1 will have a 10.60 inch center-to-center spacing and is gsigned to enriched accommodate non-irradiated, 4.2 weight percent U fuel. Region 2 will have a 9.17 inch center-to-center spacing  ;

and is designed to accommodate irradiated fuel. In either case, spacing is sufficient to maintain a suberitical condition '

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when flooded.

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ATTACEMENT 1 ,

SHOLLY EVALVATION j Missile shield Removait I i

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i Using the standards in 10 CFR 50.92, Florida Power Corporation concludes this amendment will not involve a significant hazards consideration for the following reasons: j

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1. This amendment will not involve a significant increase in the

! probability or consequences of an accident previously evaluated. During the rerack modification spent fuel in pool B will be stored in pool A with the transfer canal gate and the missile shields in place over spent fuel pool A. This rarack modification will not increase the probability of tornado-t generated missiles impacting the spent fuel pool. An

! evaluation has been performed to determine the consequences of

! tornado-generated missiles impacting the spent fuel pool gate

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while performing fuel rack densification work in pool B. The evaluation has determined that the missile spectrum utilized in the Crystal River FSAR analyses will not impact the spent ,

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fuel stored in this configuration.

i 2. This amendment will not create the poFsibility of a new or different kind of accident from any accident previously evaluated. The proposed rerack amendment has no effect on the  !

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a new or different kind of accident I possibility of creatinfously from any accident prev evaluated. The proposed change i requires the missile shields to be removed and installed over

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the A pool with the transfer canal gate in place during rarack of the B pool. All fuel will be stored in the A pool during this modification. This change cannot create a new or .

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dif ferent accident from those previously evaluatted.

3. This amendment will not involve a significant reduction in a  !

margin of safety. This is a one time relief from Technical Specification 3.9.11 to allow removal of the missile shield for installation of high density spent fuel storage racks in pool -

B. The missile shields and the transfer canal gate are Class I structures and are designed for the protection of other safety-related systems for a postulated accident. Since the missile shields will be in place over pool A with the transfer canal gate separating Pool A and B, this will prevent any damage to any of the spent fuel assemblies. Therefore, the ,

rerack modification will not involve a reduction in a margin of safety, l

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Fuel Enrichment ,

Using the standards in 10 CFR 50.92, Florida Power Corporation concludes this amendment will not involve a significant hazards -

consideration for the following reasons: i

1. This amendment will not involve a significant increase in the ,

probability or consequences of an accident previously l evaluated.

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An increase in fuel enrichment will not by itself affect the mixture of fission product nuclides. A change in fuel cycle  :

design which makes use of an increased enrichment may result in fuel burnup consisting of a somewhat different mixture of nuclides. The effect in this instance is insignificant  ;

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t a) The isotopic mixture of the irradiated assembly is  !

relatively insensitive to the assembly's initial anrichment. ,

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b) Most accident doses are such a small fraction of 10 CFR 100 limits, a large margin exists before any change becomes ,

significant.

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c) The change in Pu content which would result from an -

increase in burnup would produce more of some fission product nuclides and less of other nuclides. Small ,

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increases in some doses are offset by reductions in other doses. The radiological consequences of accidents are not significantly changed. ,

2. This amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated.

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l As indicated in the enclosed analyses, an unplanned criticality event will not occur as K will not exceed 0.95 with the ,

maximum allowable enriched duel in pool B, and flooded with unborated water.

3. This amendment will not involve a significant reduction in a margin of safety.

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While the increased enrichment in pool B may lessen the margin to criticality, this reduction is not significant because the overall safety margin is within NRC criteria of X,7f less than or equal to 0.95 (NRC Standard Review Plan, Section 9.1.2).

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spent Fuel tool marack:

Florida Power Corporation (FPC) presents this evaluation of the hazards considerations involved with the proposed amendment, focusing on the three standards set forth in 10 CFR 50.92 (c) as quoted below:

"The Commission may make a final determination, pursuant to the procedures in 50.91, that a proposed amendment to an operating license for a facility licensed under 50.21(b) or 50.22 or for a testing facility involves no significant hazards considerations, unless it finds that operation of the facility in accordance with the proposed amendment would

1. Involved a significant increase in the probability or consequences of an accident previously evaluated; or

2. Create the possibility of a new or different kind of accident from any accident previously evaluated; or

3. Involve a significant reduction in a margin of safety."

FPC submits that the activities associated with this amendment  !

request do not meet any of the significant hazards consideration i standards of 10 CFR 50.92 (c) and, accordingly, a no significant hazards consideration finding is justified. In s!apport of this .

determination, necessary background information is first provided, I followed by a discussion of each of the significant safety hazards consideration factors with respect to the proposed amendments.  !

Backcround:

The Crystal River Plant was designed and constructed with two spent I fuel storage pools. These facilities had capacity for 240 spent fuel assemblies (equive. lent to 1-2/3 of the full core fuel load).

The Crystal River Unit 3 Final Safety Analysis Report (FSAR) addressed the safety implications of the facility and included 1 relevant parameters associated with criticality, structural '

integrity, and cooling. The Crystal River Unit 3 Safety Evaluation Report (Docket No. 50-302) found the environmental and safety l impacts of storage in these facilities to be acceptable.

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In 1978, a request to amend the Crystal River operating license for increased spent fuel storage was submitted by FPC. By letter dated l November 17, 1980, the Commission approved Amendment 36 to facility operating license DPR-72 for modification to Crystal River Unit 3 spent fuel storage facility. This modification consisted of reracking the Unit 3 spent fuel pools with high density fuel l storage racks which increased the storage capacity from 240 fuel 4

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assemblies to 1153 fuel assemblies. Approval of the amendment l l i

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included a detailed review and analysis of all relevant storage i' parameters and potential accidents. The analyses resulted in a finding that environmental and safety impacts were negligible.  :

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The safety evaluation performed in support of the 1978 request to imend the Crystal River operating license to allow reracking of the i Unit 3 fuel pools addressed the following:

1. Structural and Seismic Analysis

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2. Nuclear criticality Analysis

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3. Thermal-Hydraulic Analysis

4. Accident Analyses

5. Radiation Exposures

6. Spent Fuel Cask Drop Accident  !

It was determined that the proposed modifications to the Unit 3 l

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spent fuel pools would be acceptable because: (1)- the rack structural design would withstand conditions during normal ,

operacion combined with the maximum earthquake, (2) the rack design would preclude criticality for any moderating condition,  ;

(3) the existing spent fuel cooling system was determined to f adequately cool the increased heat load, (4) the increase radiation doses, both onsite and offsite would be negligible, and (5) spent fuel cask handling operations would not change from the original design. ,

The current spent fuel storage capacity at Crystal River consists -

of 542 storage positions in spent fuel pool A and 120 storage l positions in spent fuel pool B. With this application, FPC is [

requesting approval to rerack the Crystal River spent, fuel storage  !

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pool B uo increate the storage capacity as set forth in the attached Safety Analysis Report.

Evaluatio.n 1

i The following evaluation demonstrates (by reference to the analysis I

contained in the attached Safety Analysis Report) that the proposed amendment does not exceed any of the three significant hazards ,

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consideration standards. The analysis of this proposed reracking has been accouplished using current accepted codes and standards as specified in Section 3.4 of the attached Safety Analysis Report.  ;

The results of the analysis meet the specified acceptance criteria '

in these standards as presented in the Gafety Analysis Report.

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(1) IDypive a sianificant increase in the erobability or panneauences of an accident oreviousiv evaluated. l In the course of the analysis, FPC has identified the following potential accident scenarios:

1. A spent fuel assembly drop in the spent fuel pool. )

2. Loss of spent fuel pool cooling system flow.

3. A seismic event. {

4. A spent fuel cask drop.

5. A construction accident.

The probability of any of the first four accidents is not affected by the racks themselves; thus raracking cannot increase the probability of these accidents. As for the construction accident, FPC does not intend to carry any rack directly over the stored spent fuel assemblies. All work in the spent fuel pool area will be controlled and performed in strict accordance with specific written procedures. The spent fuel cask crane which will be used to access the spent fuel pool area has been addressed in FPC's response to the NUREG- 1 0612, " Control of Heavy Loads at Nuclerir Power Plants". This l response demonstrated Crystal River compliance with Phase I of )

the NUREG-0612 criteria. By letter dated July 13, 1984, the i NRC concluded that the control of heavy loads program (Phase l I) at the Crystal River Plant was in compliance with the requirements of NUREG-0612. This program provides for the safe handling of heavy loads in the vicinity of the Spent Fuel Pool.

i Accordingly, the proposed rerack will not involve a significant increase in the probability of an accident previously -

evaluated.

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The consequences of (1) A spent fuel assembly drop in the spent fuel pool are discussed in the attached Safety Analysis Report.

For this accident condition, the criticality acceptance ,

criterion is not violated. The radiological consequences of a fuel assembly drop are not changed from that described in Chapter 14 of the Crystal River Updated FSAR. Thus, the consequences of this type accident will not be significantly  ;

increased from previously evaluated spent fuel assembly drops, and have been found acceptable by the NRC.

The consequences of (2) Loss of spent fuel pool cooling system flow, have been evaluated and are described in Section 2.2.4 of the Safety Analysis Report. As indicated in Section 2.2.4

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and 4.4 there is sufficient time to provide an alternate means )

for cooling in the event of a failure in the cooling system. )

Thus, the consequences of this type accident will not be l significantly increase from previously evaluated loss of s cooling system flow accidents. Additionally, the NRC has i previously accepted in the SER for the last rerack (duted '

11/17/80), that the cooling capacity for the CR-3 Spent fuel i pools will be sufficient to handle the incremental heat load (

that will be added by the rerack modification.  ;

The consequences of (3) A seismic event, have been evaluated I and are described in Section 3.5 of the attached Safety '

Analysis Report. The new racks will be designed and fabricated i to meet the requirements of applicable portions of the NRC Regulatory Guides and published standards listed in Section 3.4 ;

of the Safety Analysis Report. Each new rack module is provided with leveling pads which contact the spent pool floor or pool floor plates and are remotely adjustable from above,  :

through the cells, at installation. The modules are neither ,

anchored to the floor nor braced to the pool walls. The new '

racks are designed so that the floor loading from the racks  :

filled with spent fuel assemblies does not exceed the structural capacity of the Spent Fuel Building. The Spent Fuel -

Building and pool structure hpve been designed in accordance with the criteria outlined in Section 5.2 of the Crystal River Updated FSAR and previously accepted by the NRC. Thus, the consequences of a seismic event will not increase from previously evaluated events.

The consequences of (4) A spent fuel cask drop have been discussed in Section 5.3 of the Safety Analysis R8 port. Based on the . improvements in heavy loads handling obtained from I implementation of NUREG-0612 (Phase I), further action is not '

required to reduce the risks associated with the handling of heavy loads. The NRC concluded that the guidelines of Phase -

l I are adequately providing the intended level of protection l against load drop accidents. Thus, the consequences of a cask t

drop accident will not be significantly increased from previously evaluated accident analysis.

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l The consequences of (5) A construction accident are enveloped by the spent fuel cask drop analysis described in Section 5.3 ,

of the Safety Analysis Report. Missile shields that are normally in place over the spent fuel pool will remain in place over pool A, while pool B is being raracked. In addition, all movements of heavy loads handled during the rerack operation

! will comply with the NRC guidelines and ANSI 14.6. Thus, the i l

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consequences of a construction accident will not be significantly increased from previously evaluated accident analysis.

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Thus, it is concluded that the proposed amendment to rerack the  !

spent fuel pools will not involve a significant increase in the  !

probability or consequences of an accident previously  :

evaluated. [

l (2) Create the oossibility of a new or different kind of accident i from any accident oreviously evaluated. j i

FPC has evaluated the proposed raracking in accordance with the

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guidance of the NRC position paper entitled, "OT Position for Review and Acceptanca of Spent Fuel Storage and Handling Applications", appropriate NRC Regulatory Guides, appropriate NRC Standard Review Plans, and appropriate Industry Codes aid i Standards as listed in Section 3.4 of the attached Safety Analysic Report. In addition, FPC has reviewed several ,

previous NRC Safety Evaluation Reports for rarack applications  ;

similar to our proposal. As a result of thic evaluation and these reviews, FPC finds that the proposed reracking does not, l in any way, create the possibility of a new or different kind of accident from any accident previously evaluated for the Crystal River Spent Fuel Storage Facility. ,

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(3) Involve a sianificant reduction in a marain of safety.

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The NRC Staff Safety Evaluation review process has established that the issue of margin of safety, when applied to a raracking modification, will need to address the following areas.

1. Nuclear criticality considerations

2. Thermal-Hydraulic considerations

3. Mechanical, material and structural considerations The established acceptance criteria for criticality is that the ,

neutron multiplication factor in spent fuel pools shall be less than or equal to 0.95, including all uncertainties, under all conditions. This margin of safety has been adhered to in the criticality analysis methods for the new rack design as I discussed in Section 2.2 of the attached Safety Analysis Report.

The methods to be used in the criticality analysis conform with the applicable portions of the codes, standards, and specifications listed in Section 3.4 of the Safety Analysis Report. In meeting the acceptance criteria for criticality in the spent fuel pool, such that keff is always less than 0.95, including uncertainties at a 95/95 probability confide 7ce level, the proposed amendment to rerack the spent fuel pools

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Attachment 1 cont.

will not involve a significant reduction in the margin of I safety for nuclear criticality.

Conservative methods are used to calculate the maximum fuel temperature and the increase in temperature of the water in the l spent fuel pool. The thermal-hydraulic evaluation uses the l methods described in Section 2.2 of the Safety Analysis Report

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in demonstrating the temperature margins of safety are 4 maintained. The proposed raracking will allow an increase to the heat load in the spent fuel pool. The evaluation in  :

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Section 2.2 of the Safety Analysis Report shows that the existing spent fuel cooling system will maintain the pool >

temperature margins of safety for the calculated increase in ,

pool heat load. Thus, there is no significant reduction in the j margin of safety for thermal-hydraulic or spent fuel cooling .

concern.  ?

The main safety function of the spent fuel pool and the racks  !

is to maintain the spent fuel assemblies in a safe configuration through all normal and abnormal loadings, such as an earthquake, impact due to a spent fuel cask drop, drop .

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of a spent fuel assembly, or drop of any other heavy object.

The mechanical, material, and structural considerations of the proposed rarack are described in Section 3.0 of the attached ,

Safety Analysis Report. As described in Section 3.0 of the i Safety Analysis Report, the proposed racks are to be designed  !

in accordance with applicable portions of the "NRC Position for i Review and Acceptance of Spent Fuel Storage and Handling ,

Application", dated April 14, 1978, as modified January 18, ,

1979; Standard Review Plan 3.8.4; and the Crystal River Updated  !

FSAR. The rack materials used are compatible with the spent fuel pool and the spent fuel assemblies. The stru , ural l

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considerations of the new racks address margins of hafety against tilting and deflection or movement, such that the racks l do not impact each other or the pool walls, damage spent fuel l assemblies, or cause criticality concerns. Thus, the margins l of safety are not significantly reduced by the proposed rerack.

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( In summation, it has been shown that the proposed spent fuel l

storage facility modifications do not: i

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l 1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or

2. Create the possibility of a new or different kind of accident frem any accident previously evaluated; or 3.

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Involve a significant reduction in a margin of safety.

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FPC has determined and submits that the proposed amendments I described do not involve a significant safety hazard and that the i standards in 10 CFR 50.92 have been met.  ;

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