ML042870475
| ML042870475 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 10/06/2004 |
| From: | Repka D Duke Energy Corp, Winston & Strawn, LLP |
| To: | Anthony Baratta, Elleman T, Austin Young Atomic Safety and Licensing Board Panel |
| Byrdsong A T | |
| References | |
| 50-413-0LA, 50-414-0LA, ASLBP 03-815-03-OLA, RAS 8623 | |
| Download: ML042870475 (24) | |
Text
WINSTON & STRAWNLLP 1400 L STREET, N.W., WASHINGTON DC 20005-3502 202-371-5700 35W W. 06 200 t A- 36W FL 3333-0 - c 101 AC d. 43. t2 A Vd cIe M0 C- P0. I P0 0 8-Cc L 60601-0703 HI o WY 10166-4193 1- A2. CA 90071-1643 61 Pe CA c41 11-6694 zO o Oi04 - 75116 Pt
. ..w oo ECSy GT IC2 312-686-5600 21I-2944700 213-615.1700 416-591-1000 41-22-317-76-75 33-1-53-68a-62 4-207-1 fI 025 October 6, 2004 Ann Marshall Young, Chairman Anthony J. Baratta Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 DOCKrKFTF Thomas S. Elleman USNRC Administrative Judge 5207 Creedmoor Road # 101 October 13, 2004 (11:39AM)
Raleigh, N.C. 27612 OFFICE OF SECRETARY RULEMAKINGS AND Re: In the Matter of Duke Energy Corporation ADJUDICATIONS STAFF Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413-OLA, 50-414-OLA
Dear Administrative Judges:
Attached for the information of the administrative judges and the parties in this proceeding is a copy of a submittal made earlier this week by Duke Energy Corporation
("Duke") to the NRC Staff. Duke's submittal provides further information regarding the issue addressed in my correspondence of August 31, 2004, and September 20, 2004. This information does not change any of my conclusions expressed in those earlier letters.
Very truly yours, David A. Repka Counsel for Duke Energy Corporation Enclosure cc: Service List (w/Enclosure) via U.S. mail and e-mail Temlplate =ScC V- 043 sec- O9-
Ann Marshall Young, Chairman Anthony J. Baratta Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 (email: AMY(nrc.gov) (email: AJB5@nrc.gov)
Dr. Thomas S. Elleman Office of the Secretary Administrative Judge U.S. Nuclear Regulatory Commission 5207 Creedmoor Road, #101 Washington, DC 20555 Raleigh, NC 27612 Attn: Rulemakings and Adjudications Staff (e-mail: elleman(eos.ncsu.edu) (e-mail: HEARINGDOCKET(0nrc.gov)
Office of Commission Appellate Atomic Safety and Licensing Board Panel Adjudication U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Susan L. Uttal, Esq. Diane Curran Antonio Fernandez, Esq. Harmon, Curran, Spielberg &
Office of the General Counsel Eisenberg, LLP U.S. Nuclear Regulatory Commission 1726 M Street, N.W.
Washington, DC 20555 Suite 600 (e-mail: slugnrc.gov) Washington, DC 20036 (e-mail: axf2@nrc.gov) (e-mail: dcurrangharmoncurran.com)
DC:372976.3
P Duke HENRY B. BARRON rVPowere Group VP, Nuclear Generation and Chief Nuclear offcer A Duke Energy Company Duke Power EC07H / 526 South Church Street Charlotte, NC 28202-1802 Mailing Address:
P0 Box 1006 EC07H Charlotte, NC 28201-1006 October 4, 2004 704 382 2200 704 382 6056 fax hbarron@duke-energy.com Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Duke Energy Corporation Catawba Nuclear Station Units I & 2, Docket Nos. 50-413, 50414 Proposed Amendments to the Facility Operating License and Technical Specifications to Allow Insertion of Mixed Oxide (MOX) Fuel Lead Assemblies (Independent Review)
By letter dated August 31, 2004 (Reference 1), Duke informed the Nuclear Regulatory Commission (NRC) that Duke had discovered errors associated with the dose evaluations in the MOX fuel lead assembly license amendment request (LAR). Duke submitted a letter on September 20, 2004 (Reference 2) that provided corrections to LAR materials. In addition, Duke performed an independent review of the MOX fuel LAR and associated correspondence in order to provide additional assurance that the conclusions in the LAR are accurate and adequately supported. In the Reference 2 letter Duke committed to providing NRC with a summary of that review.
The independent review has been completed. The review team reached the general conclusion that the original MOX submittal, as supplemented by several Duke letters including Reference 2, provides statements that are complete, accurate, and supported by internal documentation. The independent review report is provided as Attachment 1. Exceptions and followup actions to the general conclusion are addressed in Attachment 2.
If you have any questions, please contact Steve Nesbit at (704) 382-2197.
Sincerely, H/ Ba Henry B. Barron www. dukepower. com
U. S. Nuclear Regulatory Commission October 4, 2004 Page 2 References (1) Mc Collum, W. R. (Duke), letter to U. S. Nuclear Regulatory Commission, Mixed Oxide Fuel Lead Assemblies, August 31, 2004.
(2) Barron, H. B. (Duke), letter to U. S. Nuclear Regulatory Commission, Mixed Oxide Fuel Lead Assemblies (Revised Dose Evaluations), September 20, 2004.
Attachments (2)
Attachment I - Independent Review of the MOX Lead Test Assembly License Amendment Request and Supporting Basis Documents - Exceptions to the Independent Review General Conclusion
U. S. Nuclear Regulatory Commission October 4, 2004 Page 3 cc: w/attachments Dr. William D. Travers U. S. Nuclear Regulatory Commission Regional Administrator, Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303 R. E. Martin (addressee only)
NRC Project Manager U. S. Nuclear Regulatory Commission Mail Stop O-8G9 Washington, DC 20555-0001 E. F. Guthrie Senior Resident Inspector U. S. Nuclear Regulatory Commission Catawba Nuclear Station J. B. Brady Senior Resident Inspector U. S. Nuclear Regulatory Commission McGuire Nuclear Station Diane Curran Harmon, Curran, Spielberg & Eisenberg, LLP 1726 M Street, N.W.
Suite 600 Washington, DC 20036 H. J. Porter, Director Division of Radioactive Waste Management Bureau of Land and Waste Management Department of Health and Environmental Control Columbia, SC 29201
U. S. Nuclear Regulatory Commission October 4, 2004 Page 4 bcc: w/attachments Richard Clark-DCS Marty Newdorf-DOE Guy Lunsford-DOE Don Spellman-ORNL NCMPA-1 NCEMC PMPA SRE bcc: w/attachments (via email)
S. P. Nesbit M. T. Cash F. J. Verbos J. L. Eller S. P. Schultz L. F Vaughn M. W. Scott L. J. Rudy R. L. Gill T. Shafeek-Horton J. Hoerner - Framatome ANP G. A. Meyer - Framatome ANP bcc: w/attachments (paper copy)
NRIA File/ELL - ECO50 MOX File 1607.2304 Catawba Document Control File 801.01- CN04DM Catawba RGC Date File (J. M. Ferguson - CNO 1SA)
ATTACHMENT 1 Independent Review of the MOX Lead Test Assembly License Amendment Request and Supporting Basis Documents
Independent Review of the MOX Lead Test Assembly License Amendment Request and Supporting Basis Documents September 30, 2004
/R. tGill1, Jr., Te-ams
1.0 Executive Summary In 2004, concerns were raised within Duke about the quality and accuracy of certain contents of the MOX lead test assembly license amendment request that had been submitted in February 2003. Some of the information provided in the submittal did not appear to have a reasonable supporting basis. This independent review was requested by the Manager of Nuclear Engineering to determine if the documents supporting the contents of the application provided a reasonable foundation for the statements within the submittal.
The review team was formed from personnel within Duke as well as a representative from Framatome-ANP. Several Duke personnel involved in the development of the submittal were interviewed. In addition, many engineering documents prepared in support of the submittal were reviewed.
The review team concluded that the original MOX submittal as supplemented by several Duke letters, including its letter dated September 20, 2004, provides statements that are complete, accurate, and supported by internal documentation including the revised dose calculations with the following exceptions:
- 1) Section 3.4: Technical Specification page 5.6-5 has been superceded since the February 27, 2003 original MOX LAR submittal was made. The Technical Specification page needs to be re-marked using the current version of the page (Amendments 210/204).
- 2) Appendix 3.1: The discussion regarding the ISFSI was not clear because the information presented only applied to McGuire at present, since Catawba has no ISFSI.
- 3) Appendix 3.1: Section A3.6 stated that the Catawba SFP storage racks do not take any credit for soluble boron. This is currently a true statement; however, there is a TS change submittal planned which will allow soluble boron credit to be taken.
This submittal will likely be made in 2005.
- 4) Appendix 3.1: Had more complete information been included in the original submittal, RAIs on Table A3-4 and Section A3.6 of Appendix 3.1 may have been avoided.
2.0 Introduction Duke submitted a license amendment request (LAR) to permit the installation of four mixed-oxide (MOX) fuel lead test assemblies (LTA) into either McGuire Nuclear Station or Catawba Nuclear Station in February 2003. This submittal contained generic rather than cycle specific information because at the time of submittal, Duke had not decided which unit and which fuel cycle the LTA would be loaded.
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In April 2004, a question concerning the accuracy of a statement describing the fuel in a core design was identified by the NRC staff. The question arose due to the identification of a specific fuel cycle in the fall of 2003. This question was evaluated by Duke and additional information was provided to the NRC. The staff subsequently issued a supplement to its Safety Evaluation Report that documented the results of its review of this issue.
In late August 2004, another question of accuracy within the submittal was identified by Duke. This time, the question was associated with the accuracy of certain dose calculations that had not used the correct input values. While the revised results did not affect the overall acceptability of the design, this second inaccurate statement caused a concern within Duke Management of the overall quality of the LTA submittal.
Accordingly, the Manager of Nuclear Engineering requested that an independent review team be established to thoroughly evaluate all of the documents supporting the technical contents of the LTA license amendment request and determine if these documents provide a reasonable foundation for the statements contained in the submittal and licensing correspondence in support of this request. A formal charter for this review was prepared that defined the scope of the review and the members of the review team. A copy of the charter is attached to this report.
3.0 Review Scope The charter established the scope of this independent review and the review team. The review team, identified below, was to review the supporting documentation for the contents of Attachments 3, 4, 5, and 6 of the LAR and subsequent MOX licensing correspondence and determine if they provide a reasonable foundation to support all statements made in the LAR. Supporting documents include calculations, memos, review and comment, etc.
In addition, the review team was to determine whether the LAR, subsequent MOX LTA communications with NRC, and supporting MOX LTA engineering documents were created in compliance with NSD 221, Facility Operating License & Technical Specifications Amendments/SLC/Core Operating Limits Reports/Technical Specifications Bases Changes; NSD 227, Communicating With The Nuclear Regulatory Commission; and EDM 101, Engineering Calculations/Analyses.
Licensing basis documents to be reviewed include the original submittal dated February 27, 2004, all subsequent MOX licensing correspondence, and NRC staff reports including the Safety Evaluation Report dated April 5, 2004, Supplement 2 dated July 27, 2004, NRC No Significant Hazards FR Notice dated July 12, 2004, and the NRC Environmental Assessment dated August 17, 2004.
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4.0 Review Team The review team consisted of six individuals with a diversity of backgrounds and skills who were generally independent from the MOX project team that prepared the supporting documents for the LTA submittals. The review team consisted of:
Bob Gill - Team Lead Larry Rudy, Catawba Mike Wilder, McGuire Harry Vanpelt, McGuire Mary Hazeltine, NGO Dave Dziadosz, Framatome-ANP 5.0 Review Process The standards for Duke submittals to the NRC are contained in NSD 227, Communicating with the Nuclear Regulatory Commission. This department-wide directive requires in part that the lead group preparing the submittal is responsible for overseeing the process used to establish completeness and accuracy. Completeness means that all information which the NRC might reasonably need to reach a regulatory decision has been provided. Accuracy means the reliability of information has been documented by the submittal contributors and reviewers. The specific processes to achieve these performance standards are undefined and left to the discretion of the manager responsible for the submittals.
In general, two processes for preparing submittals to the NRC are well accepted. The first, which is primarily used for quantitative information presented in a submittal, is the use of engineering calculations which require signatures from preparers, independent checkers, and management approval. Inputs, assumptions, methodologies, etc are all checked to assure quality and accuracy. The second accepted process which is used primarily for narrative or descriptive material in a submittal is the review and comment process. The draft submittal information is reviewed by multiple individuals and results in a higher quality submittal than simply having a single individual prepare the submittal.
Both processes are considered to provide reasonable assurance that the completeness and accuracy of the submitted information is sufficient for the NRC staff to make its decision.
The review team conducted the support document review by (1) interviewing personnel involved in preparing the supporting documents and (2) reviewing the supporting documents themselves. The documents reviewed included Duke calculations and topical reports as well as Framatome-ANP calculations and topical reports as well as other documents as appropriate. The list of personnel interviewed and the list of documents reviewed are provided at the end of this report.
Each member of the review team was assigned the review of a specific portion of the LAR, responses to NRC staff requests for additional information for the assigned 4
sections, all of the supporting material for the assigned sections, and interviewing the individuals responsible for all of this material. The preliminary results of the individual reviews were discussed by the team as a whole prior to finalization to permit cross-checking and assure a consistent standard. The results of these reviews are provided in the following sections.
6.0 Review Results (presented by LAR Section) 6.1 Attachment 3 - Description and Technical Justification 6.1.1 Sections 3.1-3.4 - Introduction, Description of Requested Action, McGuire and Catawba Tech Spec Changes Section 3.1 was reviewed to determine if the information contained in this section was complete and accurate. G. A. Copp (employed by Duke Energy at the time of submittal) was interviewed regarding the information contained in this section.
Based on the review of the information contained in Section 3.1 and the interview results, the review team concluded that Section 3.1 was complete, accurate, and supported by internal documentation.
Section 3.2 was reviewed to determine if the information contained in this section was complete and accurate. The review team concluded that Section 3.2 was complete, accurate, and supported by internal documentation.
Section 3.3 was not reviewed because the McGuire portion of the LAR was subsequently withdrawn. Catawba's Technical Specification changes (Section 3.4) were reviewed and will be discussed below.
Section 3.4 was reviewed to determine if the information contained in this section was complete and accurate. It was noted that the markup insert on TS page 4.0-2 and the italicized material in Attachment 3, Section 3.4.3.1 are not exactly alike.
Differences were determined to be only editorial with no change in meaning.
Attachment 2 (Marked Copy of Catawba Technical Specifications and Associated Bases Changes) of the February 27, 2003 original MOX LAR submittal (Document 8.1-1) was also reviewed. Markups are correct regarding technical content; however, TS page 5.6-5 has been superceded since the February 27, 2003 original MOX LAR submittal was made. The TS page needs to be re-marked using the current version of the page (Amendments 210/204). Document 8.2-1 (OP/0/A/6550/010, Receipt, Unloading, Inspecting, and Storage of New MOX Fuel Lead Assemblies (LAs), approved on 6/30/04) was reviewed for consistency with information given in Section 3.4.1.1 which discussed MOX fuel assembly receipt, inspection, and SFP loading. The review team concluded that Section 3.4 was complete, accurate, and supported by internal documentation.
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6.1.2 Section 3.5 - Description of MOX Fuel Lead Assemblies Section 3.5 was reviewed for completeness and accuracy of information contained in the February 27, 2003 original MOX LAR submittal (Document 8.1-1).
Supporting and/or supplementary information (Documents 8.1-1 through 8.1-3, and 8.3-1 through 8.3-6) was reviewed to aid in making this determination. An interview was conducted with S. P. Nesbit in conjunction with the review of Section 3.5. The information in Section 3.5 is primarily based on Topical Reports BAW-10238 and 10239 and their supporting references. The technical information given in Section 3.5 is judged to be accurate and complete. This conclusion is further supported by the NRC Safety Evaluations (SEs) for the unaccepted Topical Reports referenced by Section 3.5. The SEs (Documents 8.3-2 through 8.3-6) were reviewed to ensure that any conditions and/or limitations imposed by the NRC did not invalidate the information supplied in the submittal.
The accepted versions of these Topical Reports were consistent with the information used from the unaccepted Topical Reports used to generate the inputs to Section 3.5 of the submittal. The review team concluded that Section 3.5 was complete, accurate, and supported by internal documentation.
6.1.3 Section 3.6 - Effects of MOX Fuel on Plant Operations Section 3.6 was reviewed to determine if the information contained in this section was complete and accurate. Interviews were conducted with G. A. Copp, S. P.
Nesbit, Jim Eller and Scott Thomas in conjunction with the review of Section 3.6.
Section 3.6.1 (Reactor Vessel) was reviewed with regard to aging effects on the reactor vessel as well as other components (e.g., CRDMs, nuclear instrumentation, internals, etc.) that result from increased radiation exposure from increased fast neutron flux. Document 8.2-3 (DPC-1607.00-00-0008, MOX Core Designs for LTA/Equilibrium Core Analyses) and other related docketed material were reviewed to determine if the analyses supported the information in Section 3.6.1. The review team concluded that Section 3.6.1 was complete, accurate, and supported by internal documentation.
Tables 3-7 through 3-10 of Section 3.6.2 (Nuclear Design) were reviewed along with the supporting basis (Document 8.24, DPC-1607.00-00-0015, Physics Parameters Comparisons for LTA and Non-LTA Cores (MOX)). It was concluded that the docketed values were consistent with the calculated values.
Any differences found were attributed to round-off.
Section 3.6.3 (Thermal Hydraulic and Mechanical Design) was reviewed with respect to mixed core effects, specifically a core composed of MOX LTAs, Westinghouse "next generation fuel" (NGF), and Westinghouse Robust Fuel Assemblies (RFAs). A supplement to the LAR dated June 17, 2004 (Document 8.1-11) and the SER dated July 27, 2004 (Document 8.1-12) concluded that the NGF is basically equivalent to the RFA.
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Information related to Fuel Handling (Section 3.6.4) was reviewed. Specific areas that were reviewed included the shipping package, existing plant equipment (e.g.,
cranes, etc.), procedures and doses from a fresh MOX fuel assembly. It was concluded that all information with the exception of the dose information supported the information given in Section 3.6.4. Verification of dose information was performed after the review was completed. It was verified that the dose information was correct.
Section 3.6.5 (Security) was reviewed and found to complete and accurate. A revision to the Duke Power Company Nuclear Security and Contingency Plan addressing MOX was submitted on September 15, 2003.
The review team concluded that Section 3.6 was complete, accurate, and supported by internal documentation.
6.1.4 Section 3.7 - Safety Analysis of MOX Fuel Assemblies Section 3.7.1 (LOCA) of the February 27, 2003 original MOX LAR submittal (Document 8.1-1) was reviewed for completeness and accuracy of information.
An interview was conducted with Bob Harvey in conjunction with the review of Section 3.7.1. Supporting andlor supplementary information (Documents 8.2-5 through 8.2-7) was also reviewed. The information in Section 3.7.1 is primarily based on the documents above and the supporting references for Section 3.7.1.
The review team concluded that Section 3.7.1 was complete, accurate, and supported by internal documentation.
Section 3.7.2 (Non-LOCA) of the submittal was reviewed for completeness and accuracy of information. An interview was conducted with Mike Scott in conjunction with the review of Section 3.7.2. Topical Report DPC-NE-3001P-A (Document 8.3-7) was used as the basis for determining what accidents were re-analyzed. Document 8.2-20 (DPC-1552.08-00, MOX LTA Core Rod Ejection Accident Fuel Enthalpy Calculation) was reviewed which supported the reported results. Other transients and accidents that are sensitive to local physics parameters were also evaluated. The review team concluded that Section 3.7.2 was complete, accurate, and supported by internal documentation.
Section 3.7.3 (Radiological Consequences of Postulated Accidents) of the submittal was reviewed for completeness and accuracy of information. The review team confirmed that the dose calculations reported in Section 3.7.3 of the initial submittal had not used the correct input values nor had they been properly reviewed and approved. Interviews were conducted with Mark Costello, Jay Verbos and Steve Schultz in conjunction with the review of Section 3.7.3. The interviews focused on the history of the dose work leading up to and during the initial submittal, the causes leading to the misapplication of information in the initial submittal, and the review of the revised dose calculations. The causes for 7
the inaccurate information were determined to be 1) the UFSAR dose information did not reflect the current design basis (i.e., UFSAR updates were not performed for dose calculation changes) and 2) errors were discovered in the control room LOCA dose calculation which was used to support the initial submittal (i.e.,
inadequate review and documentation of calculations).
In addition to the review of Section 3.7.3, other related licensing documents (Documents 8.1-2, 8.1-5 through 8.1-8) were also reviewed. The dose calculations in Documents 8.2-9 through 8.2-19 were reviewed. Summaries of the revised dose calculations were subsequently submitted to the NRC by Duke letter dated September 20, 2004. The review team concluded that Section 3.7.3 of the original submittal as revised by Duke letter dated September 20, 2004 was now complete, accurate, and supported by documentation, including the newly revised dose calculations.
6.1.5 Section 3.8 - Risk Impact of MOX Fuel Assemblies Section 3.8 was reviewed to determine if the information contained in this section was complete and accurate. Interviews were conducted with P. D. Paul and M.
S. Kitlan. A review of this section revealed that it contained only generalized statements concerning MOX LTA impact on overall plant risk. Items briefly discussed included fuel characteristics, assembly decay heat, radionuclide inventory, etc. The section made general references to source documents to substantiate statements. Severe Accident Analysis was not required to perform any detailed analytical work to support the generalized statements made in the February 27, 2003 original MOX LAR submittal (Document 8.1-1). The interviewee recalled that the group manager provided the general input to the MOX group for the original submittal for this section. At the time, the group manager requested the interviewee to perform minor calculations to support this section; however, this work was not formally documented in a calculational file.
Rather, it resided on the interviewee's personal computer. Severe Accident Analysis did perform detailed analytical work in response to a contention filed by BREDL. This work was formally documented in a calculational file. The review team concluded that Section 3.8 was complete, accurate, and supported by internal documentation.
6.1.6 Appendix 3.1 - Criticality Evaluation of MOX Fuel Storage in the McGuire and Catawba Spent Fuel Pools Appendix 3.1 was reviewed to determine if the information contained in this section was complete and accurate. An interview was conducted with J. P.
Coletta in conjunction with the review of Appendix 3.1. Documents 8.1-1 and 8.2-2 were also reviewed. Section A3.2 discussed the ISFSI. The discussion regarding the ISFSI was not clear that the information presented only applied to 8
McGuire at present, since Catawba has no ISFSI. No source references were given for the material in Tables A3-1 and A3-2; however, they were easily traced back to the calculation. Section A3.6 stated that the Catawba SFP storage racks do not take any credit for soluble boron. This is currently a true statement; however, there is a TS change submittal planned which will allow soluble boron credit to be taken. This submittal will likely be made in 2005.
Table A3-4 did not list all of the uncertainties that were contained in the calculation. They were later provided to NRC as part of an RAI response.
Section A3.6 did not explicitly state the numerical results. This section stated that for McGuire and Catawba that the worst case 95/95 keff was below the 0.95 limit, but did not quantify results. The NRC requested the specific results in an RAI.
Had more complete information been included in the original submittal, these RAls may have been avoided.
Further clarification on the ISFSI discussion (i.e., Catawba has no ISFSI) and the future use of soluble boron credit in Catawba SFP should be made to the NRC.
With the exception of these items, the review team concluded that Appendix 3.1 was complete, accurate, and supported by internal documentation.
6.2 Attachment 4 - No Significant Hazards Consideration Evaluation Attachment 4 was reviewed for accuracy and completeness. An interview was conducted with Mike Cash in conjunction with the review of Section 3.7.2. Areas investigated included failure rates of the Mark-BW fuel assembly design which is the basis for the MOX LTA design, physical dimensions and ability to handle the MOX LTAs, dose consequences and spent fuel handling accident for a MOX LTA. All information obtained through documentation and interviews supported the information contained in Attachment 4. The exception was dose consequences which were being updated during the review due to previous discrepancies. The review team concluded that Attachment 4 was complete, accurate, and supported by internal documentation and the revised dose information. The revised dose analyses (Document 8.1-9) were completed and transmitted to the NRC on September 20, 2004. Attachment 6 of the September 20, 2004 submittal updated the information contained in the No Significant Hazards Consideration Evaluation.
6.3 Attachment 5 - Environmental Report for MOX Fuel Lead Assemblies Attachment 5 was prepared using information gleaned from previous environmental reviews and from analyses provided in the MOX LAR submittal.
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The previous environmental reports reviewed include the Surplus Plutonium Final Environmental Impact Statement, DOE/EIS-0283; the Storage and Disposition of Weapons-Usable Fissile Materials Final Programmatic Environmental Impact Statement, DOE/EIS-0229; and the Final Environmental Impact Statement for a Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste at Yucca Mountain DOE/EIS-025F.
Section 5.6.2, Impacts to Human Health, includes quantitative information from Section 3.6.4, Fuel Handling. Section 5.6.3, Impacts of Postulated Accidents is based entirely on the technical information provided in the MOX LAR submittal.
In addition to the above, Attachment 5 was prepared using the standard review and comment resolution process. The draft attachment was reviewed by the MOX project personnel, key subject matter experts as well as legal review.
Comments were resolved and ultimately the final version was submitted.
Following the submittal of the Environmental Report and the staff review, a number of requests for information (RAIs) were formally transmitted to Duke.
Discussions with Mike Cash indicated that these questions were from the environmental reviewer who was under schedule pressure to get the environmental assessment published. The information provided, by Duke from existing submitted material, was checked by both Steve Nesbit and the legal team.
The review team concluded that Attachment 5 was complete, accurate, and supported by internal documentation.
Attachment 7 of the September 20, 2004 submittal (Document 8.1-9) updated the information contained in the Environmental Report for MOX Fuel Lead Assemblies.
6.4 Attachment 6 - Request for Exemptions from Certain Provisions of 10 CFR Part 50 The information contained in Attachment 6 was reviewed for accuracy and completeness. The information (i.e., applicable NRC standard, identification of specific regulations, scope of the proposed exemption, and justification for the exemption) provided in Attachment 6 is consistent with the requirements to request exemptions from certain regulations contained in 10 CFR Part 50. The review team concluded that Attachment 6 was complete, accurate, and supported by internal documentation.
6.5 Conclusions Attachments 3 through 6 of the February 27, 2003 original MOX LAR submittal (Document 8.1-1) were reviewed for accuracy and completeness. The review process was performed by reviewing the relevant supporting documentation and interviewing cognizant personnel. The review team concluded that the original 10
MOX submittal as supplemented by several Duke letters, including its letter dated September 20, 2004, provides statements that are complete, accurate, and supported by internal documentation including the revised dose calculations with the following exceptions:
- 1) Section 3.4: Technical Specification page 5.6-5 has been superceded since the February 27, 2003 original MOX LAR submittal was made. The Technical Specification page needs to be re-marked using the current version of the page (Amendments 210/204).
- 2) Appendix 3.1: The discussion regarding the ISFSI was not clear because the information presented only applied to McGuire at present, since Catawba has no ISFSI.
- 3) Appendix 3.1: Section A3.6 stated that the Catawba SFP storage racks do not take any credit for soluble boron. This is currently a true statement; however, there is a TS change submittal planned which will allow soluble boron credit to be taken. This submittal will likely be made in 2005.
- 4) Appendix 3.1: Had more complete information been included in the original submittal, RAIs on Table A3-4 and Section A3.6 of Appendix 3.1 may have been avoided.
7.0 Personnel Interviewed Listed below are personnel interviewed by the review team during the review process.
G. A. (Skip) Copp J. P. Coletta S. P. Nesbit Scott Thomas J. Eller Ted Bowling P. D. Paul Bob Harvey M. S. Kitlan Mike Cash Mark Costello Mike Scott Steve Schultz Jay Verbos 8.0 Documents Reviewed 8.1 Docketed Correspondence 8.1-1. Letter from M. S. Tuckman to U. S. Nuclear Regulatory Commission, "Proposed Amendments to the Facility Operating License and Technical Specifications to Allow Insertion of Mixed Oxide (MOX) Fuel Lead Test Assemblies and Request for Exemption from Certain Regulations in 10 CFR Part 50", dated February 27, 2003.
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8.1-2. Letter from H. B. Barron to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding the Use of Mixed Oxide Lead Fuel Assemblies", dated November 3, 2003.
8.1-3. Letter from U. S. Nuclear Regulatory Commission to H. B. Barron, "Safety Evaluation for Proposed Amendments to the Facility Operating License and Technical Specifications to Allow Insertion of Mixed Oxide Fuel Lead Assemblies" (TAC No. MB7863, MB7864, MC0824, and MC 0825), dated April 5, 2004.
8.1-4. NRC FONSI / Environmental Assessment, 69 FR 51112 dated August 17, 2004.
8.1-5. Letter from K. S. Canady to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information dated November 21, 2003 Regarding Mixed Oxide Fuel Lead Assemblies (TAC Nos.
MB7863, MB7864)", dated December 10, 2003.
8.1-6. Letter from W. R. McCollum to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information (TAC Nos. MB7863, MB7864) Mixed Oxide Fuel Lead Assemblies (Environmental, Radiological and Materials)", dated February 2, 2004.
8.1-7. Letter from H. B. Barron to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information (TAC Nos. MB7863, MB7864) Mixed Oxide Fuel Lead Assemblies (Environmental)", dated March 1, 2004.
8.1-8. Letter from W. R. McCollum to U. S. Nuclear Regulatory Commission, "Amended Information Regarding Radiological Consequences for MOX Fuel Lead Assemblies", dated March 16, 2004.
8.1-9. Letter from H. B. Barron to U. S. Nuclear Regulatory Commission, "Proposed Amendments to the Facility Operating License and Technical Specifications to Allow Insertion of Mixed Oxide (MOX) Fuel Lead Assemblies (Revised Dose Evaluations)", dated September 20, 2004.
8.1-10. Catawba Technical Specifications and Bases (Amendments 210/204).
8.1-11. Letter from H. B. Barron to U. S. Nuclear Regulatory Commission, "Proposed Amendment to the Facility Operating License and Technical Specifications to Allow Insertion of Mixed Oxide (MOX) Fuel Lead Assemblies (Next Generation Fuel-Response to Request for Additional Information)", dated June 17, 2004.
8.1-12. Letter from U. S. Nuclear Regulatory Commission to H. B. Barron, "Supplement 2 to Safety Evaluation for Proposed Amendments to the Facility Operating License and Technical Specifications to Allow Use of Mixed Oxide Fuel Lead Assemblies (TAC Nos. MB7863 and MB7864)", dated July 27, 2004.
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8.2 Engineering Documents 8.2-1. OP/0/A/6550/010, Receipt, Unloading, Inspecting, and Storage of New MOX Fuel Lead Assemblies (LAs).
8.2-2. DPC-1553.12-00-0007, Criticality Analysis for Wet Storage of MOX Lead Test Assemblies.
8.2-3. DPC-1607.00-00-0008, MOX Core Designs for LTAlEquilibrium Core Analyses.
8.2-4. DPC-1607.00-00-0015, Physics Parameters Comparisons for LTA and Non-LTA Cores (MOX).
8.2-5. DPC-1552.08-00-0185, Westinghouse Fuel LOCA Inputs.
8.2-6. 86-5028231-02, MOX Lead Assembly LOCA Summary Report.
8.2-7. 51-5045912-00, Supplemental RAI on MOX LA LOCA Analysis.
8.2-8. ORNL Report, Updated Route and Population Density Information to Support MOX Lead Assembly Fuel Qualification by Eurofab, dated 01/31/2002.
8.2-9. CNC-1227.00-00-0115, Radiological Impact Analyses of Postulated Fuel Handling Accident and Weir Gate Drop Accident Involving Mixed Oxide Fuel Assemblies.
8.2-10. CNC-1227.00-00-0042, Locked Rotor Offsite Dose Analysis.
8.2-11. CNC-1227.00-00-0074, Dose Analysis Calculation for Unit 2 Modification CN-21371/0.
8.2-12. CNC-1227.00-00-0080, Dose Analysis Calculation for Unit 1 Modifications CN-1 1383/0.
8.2-13. CNC-1227.00-00-0123, Fuel Handling and Weir Gate Drop Accidents Involving Spent MOX Fuel Assemblies.
8.2-14. CNC-1227.00-00-0112, Effect of Asymmetric Flow Split for the VC Outside Air Intake Lines on Radiation Doses Following Fuel Handling Accidents and Weir Gate Drop.
8.2-15. CNC-1227.00-00-01 11, Radiological Impact Analysis of Postulated Fuel Handling Accidents.
8.2-16. CNC-1227.00-00-01 10, Radiological Impact Analysis of a Postulated Spent Fuel Pool Weir-Gate Drop Accident.
8.2-17. CNC-1227.00-00-0045, Offsite Dose Analysis, FSAR Basis.
8.2-18. CNC-1227.00-00-0009, Control Room LOCA Dose.
8.2-19. DPC 1227.00-00-0017, MOX Licensing Correspondence Dose Related Inputs.
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8.2-20. DPC-1552.08-00, MOX LTA Core Rod Ejection Accident Fuel Enthalpy Calculation.
8.3 Topical Reports 8.3-1. BAW-10238(NP), Revision 1, "MOX Fuel Design Report", dated May 2003.
8.3-2. Letter from U. S. Nuclear Regulatory Commission to J. F. Mallay, Final Safety Evaluation for Framatome ANP Topical Report BAW-10238(P), Revision 1, "MOX Fuel Design Report" (TAC No.
MB7550), dated July 1, 2004.
8.3-3. Letter from U. S. Nuclear Regulatory Commission to J. F. Mallay, Final Safety Evaluation for Framatome ANP Topical Report BAW-10239(P), Revision 0, "Advanced Mark-BW Fuel Assembly Mechanical Design Topical Report" (TAC No. MB755 1), dated July 1, 2004.
8.3-4. Letter from U. S. Nuclear Regulatory Commission to J. F. Mallay, Final Safety Evaluation for Topical Report BAW- 10231 P, "COPERNIC Fuel Rod Design Code" Chapter 13, MOX Applications (TAC No.
MB7547), dated January 14, 2004.
8.3-5. Letter from U. S. Nuclear Regulatory Commission to J. F. Mallay, Safety Evaluation of Framatome ANP Topical Report BAW-1010186P-A, Revision 1, Supplement 1, "Extended Burnup Evaluation" (TAC Nos.
MB3650 and MB7548), dated June 18, 2003.
8.3-6. Letter from U. S. Nuclear Regulatory Commission to T. A. Coleman Revised Safety Evaluation (SE) for Topical Report BAW-10227P:
"Evaluation of Advanced Cladding and Structural Material (M5) in PWR Reactor Fuel" (TAC No. M99903), dated February 4, 2000.
8.3-7. DPC-NE-3001P-A, "Duke Power Company, McGuire Nuclear Station, Catawba Nuclear Station, Multidimensional Reactor Transients and Safety Analysis Physics Parameters Methodology," Duke Power Company, November 1991.
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Charter for the Independent Review of the MOX Lead Test Assembly License Amendment Request and Supporting Basis Documents REQUESTED BY:
Tom Geer, Manager, Nuclear Engineering, Nuclear Generation Department PURPOSE:
Determine if the documents supporting the technical contents of the Lead Test Assembly License Ainendinent Request (LAR) provide a reasonable foundation for the statements contained in the LAR.
REVIEW SCOPE:
- 1. Review the supporting documentation for the contents of Attachments 3,4, 5, and 6 of the LAR and subsequent MOX licensing correspondence and determine if they provide a reasonable foundation to support all statements made in the LAR. Supporting documents include calculations, memos, review and comment, etc.
- 2. Determine whether the LAR, subsequent MOX LTA cominunications with NRC, and supporting MOX LTA engineering documents were created in compliance with NSD 221, Facility Operating License & Technical Specifications Amendments/SLC/Core Operating Limits Reports/Technical Specifications Bases Changes; NSD 227, Communicating With The Nuclear Regulatory Commission; and EDM 101, Engineering Calculations/Analyses.
- 3. Licensing basis documents to be reviewed include the original submittal dated February 27, 2004, all subsequent MOX licensing correspondence, and NRC staff reports including the Safety Evaluation Report dated April 5,2004, Supplement 2 dated July 27,2004, NRC No Significant Hazards FR Notice dated July 12,2004, and the NRC Environmental Assessment dated August 17, 2004.
REVIEW TEAM: MANAGEMENT STEERING TEAM:
Bob Gill - Team Lead Jim Fisicaro Larry Rudy, Catawba Tom Geer Mike Wilder, McGuire Jim Kammer Harry Vanpelt, McGuire Mary Hazeltine, NGO Dave Dziadosz, Frainatome-ANP '
REPORT TO STEERING TEAM The Review Teain will hold report the results of its review to the Steering Teain on or before September 23,2004, and provide its final report by October 1, 2004.
BUSINESS CONSIDERATION:
Labor expenses will be charged to an aljprGpriate accoiliit provided by the MOX project.
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ATTACHMENT 2 Exceptions to the Independent Review General Conclusion
ATTACHMENT 2 Exceptions to the Independent Review General Conclusion Section 1.O of the Independent Review Report lists four exceptions to the general conclusion that the MOX firel lead assembly license amendment request and associated documentation is complete, accurate, and supported by internal documentation. Each exception is addressed in the following table.
Excention Resolution Section 3.4: Technical Specification page This NRC Project Manager has been made 5.6-5 has been superceded since the aware of this item. Catawba Compliance has February 27,2003 original MOX LAR provided NRC with an up-to-date electronic submittal was made. The Technical version of page 5.6-5 (reflecting Specification page needs to be remarked Amendments 2 10/204) for iise in the MOX using the current version of the page fuel lead assembly license amendment.
(Amendments 2 10/204).
Appendix 3. I : The discussion regarding No further clarification is required because the ISFSI was not clear because the the license amendment request has been information presented only applied to amended to apply to Catawba only.
McGuire at present, since Catawba has no ISFSI.
Appendix 3.1 : Section A3.6 stated that the When submitted, the Catawba license Catawba SFP storage racks do not take amendment request associated with soluble any credit for soluble boron. This is boron credit will address the impact of MOX currently a true statement; however, there fuel assemblies.
is a TS change submittal planned which will allow soluble boron credit to be taken. This submittal will likely be made in 2005.
Appendix 3.1 : Had more complete No further action is required with respect to information been included in the original the MOX fuel lead assembly license submittal, RAIs on Table A3-4 and amendment request.
Section A3.6 of Appendix 3.1 may have been avoided.
In addition to the specific resolutions noted above, Duke plans to incorporate lessons-learned from the Independent Review and the entire MOX he1 lead assembly license amendment request process into the development of the license amendment request for batch use of MOX fuel.
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