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WAIS Document Retrieval <br />pool boiling resulting in uncovering fuel assemblies. This situation <br />would lead to fuel failure and subsequent significant increase in <br />offsite dose. Loss of spent fuel pool cooling at Harris is mitigated <br />in the usual manner by ensuring that a sufficient time lapse exists <br />between the loss of forced cooling and uncovering fuel. This period <br />of time is compared against a reasonable period to re- establish <br />cooling or supply an alternative water source. Evaluation of this <br />accident usually includes determination of a time to boil, which in <br />the case of pools 'C' and 'D' is in excess of 13 hours based on a <br />consideration of end of plant life heat loads. This evaluation <br />neglects any possible cooling from the connection to pools 'A' and <br />'B' through the transfer canal. The 13 hour period is much shorter <br />than the onset of any significant increase in offsite dose, since <br />once boiling begins it would have to continue unchecked until the <br />pool surface was lowered to the point of exposing active fuel. The <br />time to boil represents the onset of loss of pool water inventory <br />and is commonly used as a gauge for establishing the comparison of <br />consequences before and after a refueling project. The heatup rate <br />in the Spent Fuel Pool is a nearly linear function of the fuel decay <br />heat load. Subsequent to the proposed changes, the fuel decay heat <br />load will increase because of the increase in the number assemblies <br />from those considered from Pools 'A' and 'B' alone. The methodology <br />used in the thermal- hydraulic analysis determined the maximum fuel <br />decay heat loads. In the unlikely event that pool cooling is lost to <br />pools 'C' and 'D', sufficient time will still be available for the <br />operators to provide alternate means of cooling before the onset of <br />pool boiling. Therefore, the proposed change represents no increase <br />in the consequences of loss of pool cooling. <br />The consequences of a design basis seismic event are not <br />increased. The consequences of this accident are evaluated on the <br />basis of subsequent fuel damage or compromise of the fuel storage or <br />building configurations leading to radiological or criticality <br />concerns. The new racks have been analyzed in their new <br />configuration and found safe during seismic motion. The fuel stored <br />in these racks has been determined to remain intact and the racks <br />maintain the fuel and fixed poison configurations subsequent to a <br />seismic event. The structural capability of the pool and liner will <br />not be exceeded under the appropriate combinations of dead weight, <br />thermal, and seismic loads. The Fuel <br />[[Page 2239]] <br />Handling Building structure will remain intact during a seismic <br />event and will continue to adequately support and protect the fuel <br />racks, storage array, and pool moderator /coolant. Thus, the <br />consequences of a seismic event are not increased. <br />Fuel misloading and mislocation accidents were previously <br />credible occurrences, since fuel could be placed at an unintended <br />storage location or could have been lowered outside and adjacent to <br />a storage rack in Pools 'A' or 'B'. However, neither of these two <br />scenarios previously represented any concern because of the flux <br />trap style of the rack designs in these two pools. Similar <br />procedures, equipment and methods of fuel movement will be used for <br />Pools 'C' and 'D' as those used previously for Pools 'A' and 'B'. <br />Therefore, the proposed activity does not represent any increase in <br />the probability of occurrence. The proposed non -flux trap design <br />racks for Pools 'C' and 'D' require administrative controls to <br />ensure that fuel assemblies meet effective enrichment criteria prior <br />to storage. Under these conditions, misloading of a fuel assembly by <br />placement in an unintended storage cell has no significant <br />consequences. Therefore, the only remaining potential mislocation of <br />a fuel assembly is for an assembly to be lowered outside of and <br />directly adjacent to a storage rack. This accident occurring in <br />Pools 'C' or 'D' has been analyzed for the worst possible storage <br />Page 3 of 8 <br />http: / /frwebgate2. acces ... /waisgate.cgi ?WAISdocID= 341284846 +0 +0 +0 &WAISaction = retriev 1/14/99 <br />