05000445/FIN-2012004-03
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Finding | |
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| Title | Potential Failure to Follow 10 CFR 50.59 for a Change to the Spent Fuel Pool Configuration |
| Description | On August 28, 2007, the licensee submitted an application for a license amendment for a stretch power uprate of reactor power of approximately six percent power. Included in this application was a proposed change to Technical Specification 3.7.17 to support the eventual loading of the power uprate fuel to the spent fuel pool, and associated criticality analyses. For ease of review, the review of the spent fuel pool criticality analysis was separated from the stretch power uprate review. On June 27, 2008, the license amendment approving the licensed reactor power uprate was issued. On June 30, 2008, based on an NRC technical staff request, the licensee submitted additional information for the spent fuel pool criticality analysis amendment. On November 19, 2008, a formal request for additional information was issued by the NRC for the spent fuel pool criticality analysis amendment. During 2008 and 2009, the licensee submitted several separate responses to the request for additional information questions. On July 10, 2009, the NRC technical staff issued a draft denial letter of the spent fuel pool criticality analysis amendment. On August 20, 2009, in response to the draft denial of the license amendment, the licensee formally withdrew the license amendment, which was acknowledged by the NRC the next day. As of May 14, 2012, no further correspondence was submitted by the licensee to pursue a license amendment for uprated fuel storage in the spent fuel pool. Both Units 1 and 2 operated for two entire refueling intervals (18 months) from 2009 to 2012 at the uprated reactor power conditions. However, the licensee had not resolved the issues associated with receiving a license amendment to allow for storage of the uprated fuel in the spent fuel pool. In February 2009, the licensee performed a 10 CFR 50.59 screening of Procedure NUC-211 to address the potential storage of uprated fuel in the spent fuel pools if a license amendment was not approved by the end of the operating cycle. The licensee added a precaution to Procedure NUC-211 stating, in part, that fuel assemblies from Unit 1 Cycle 14 and beyond and assemblies from Unit 2 Cycle 12 and beyond, should not be stored in Region II until the technical specifications are revised to consider the effects of stretch power uprate conditions. The inspectors considered this precaution to be appropriate, because the Region II high density storage racks technical specifications implement a number of limitations on storage configurations based on fuel enrichment and fuel burnup. Procedure NUC-211 did allow for storage of uprated fuel in the low density fuel racks, which was analyzed for any storage configuration regardless of fuel enrichment. The precautions of Procedure NUC-211, prohibiting the storage of uprated fuel in Region II of the spent fuel pool, remained in effect for the duration of the first operating cycles following the approval of the power uprate. The first storage of Unit 1 uprated fuel to Region I (the low density-unrestricted racks) of the spent fuel pool occurred on April 3, 2010, following Unit 1 Cycle 14. However, the licensee determined that the spent fuel pools did not have sufficient capacity for the placement of all fuel in Region I of the spent fuel racks and accommodate other fuel management considerations. Therefore, the licensee contacted a vendor to analyze the movement of the uprated fuel to Region II of the spent fuel racks. On September 29, 2010, the vendor provided the licensee with the results of this analysis. This analysis stated that the burnup versus enrichment curves for Technical Specification 3.7.17, for storage of fuel in Region II of the spent fuel racks, were nonconservative when applied to fuel depleted at uprated conditions. The uprated fuel remained in Region I (unrestricted low density racks) because of this information. The vendor letter provided the licensee with proposed fuel burnup penalties to account for uprate conditions should the licensee desire to move the uprated spent fuel to Region II of the spent fuel pools. In December 2010, the licensee relocated uprated spent fuel from Region I to Region II of the spent fuel pools. Because the fuel discharge curves for spent fuel subject to uprated conditions of Technical Specification 3.7.17 were nonconservative, the licensee erroneously invoked the direction of NRC Administrative Letter 98-10, Dispositioning of Technical Specifications That Are Insufficient to Ensure Plant Safety. The licensee noted that the NRC letter states that if a technical specification is found to be nonconservative, administrative controls to ensure nuclear safety is adequately protected is an acceptable short-term solution. The licensee erroneously believed that these compromise solutions of the administrative letter applied equally to current and past plant design as well as a desired future plant configuration. Therefore, on December 15, 2010, the licensee revised Procedure NUC-211, to allow storage of uprated fuel in Region II of the spent fuel pools using the unreviewed or unapproved methodology and fuel burnup penalties. The 10 CFR 50.59 screening incorrectly stated that a technical specification amendment was unnecessary. This method of applying burnup penalties was not analyzed, and was not reviewed or approved by the NRC. The inspectors concluded that Technical Specification 3.7.17 was not valid for storage of uprated fuel in Region II of the spent fuel pools, and not permitted by the provisions of 10 CFR 50.59. The licensees change to Procedure NUC-211 that allowed the use of administrative controls to discharge uprated fuel to Region II of the spent fuel pools without prior NRC approval was considered a potential violation of 10 CFR 50.59. However, additional NRC review and follow-up is necessary to fully characterize the performance deficiency. Therefore, this issue is being treated as an unresolved item: URI 05000445/2012004-03; 05000446/2012004-003, Potential Failure to Follow 10 CFR 50.59 for a Change to the Spent Fuel Pool Configuration. |
| Site: | Comanche Peak  |
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| Report | IR 05000445/2012004 Section 1R18 |
| Date counted | Sep 30, 2012 (2012Q3) |
| Type: | URI: Green |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.18 |
| Inspectors (proximate) | D Proulx G Guerra J Kramer J Watkins L Brandt L Carson N Greene R Kumana S Alferink W Sifre W Walkerg Guerraw Walker B Tindell D Proulx J Kramer K Wood |
| INPO aspect | |
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Finding - Comanche Peak - IR 05000445/2012004 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Comanche Peak) @ 2012Q3
Self-Identified List (Comanche Peak)
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