ML090210011

Acceptance Review Regarding Amendment to Remove Credit for Boraflex in BWR Spent Fuel Pool Storage Racks

ML090210011
Person / Time
Site:	Harris
Issue date:	01/27/2009
From:	Vaaler M Plant Licensing Branch II
To:	Burton C Carolina Power & Light Co
Vaaler, Marlayna, NRR/DORL 415-1998
References
TAC ME0012
Download: ML090210011 (3)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 27,2009 Chris L Burton, Vice President Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 -ACCEPTANCE REVIEW OF PROPOSED AMENDMENT TO REMOVE CREDIT FOR BORAFLEX IN BOILINGWATER REACTOR SPENT FUEL POOL STORAGE RACKS (TAC NO. ME0012)

Dear Mr. Burton:

By letter dated September 29, 2008 (Agencywide Documents Access and Management System Accession No. ML082800410), Carolina Power and Light Company, now doing business as Progress Energy Carolinas, Inc. (PEC), submitted a proposed amendment for the Shearon Harris Nuclear Power Plant, Unit 1 (HNP).

The proposed amendment would modify Technical Specification (TS) Sections 5.6.1.3.a and 5.6.1.3.b to incorporate the results of a new criticality analysis. Specifically, the TSs would be revised to add new requirements for the Boiling Water Reactor (BWR) spent fuel storage racks containing Boraflex in Spent Fuel Pools A and B. The requirements for the BWR spent fuel racks as currently contained in TS 5.6.1.3 would be revised to specify applicability to the spent fuel storage racks containing Boral in Spent Fuel Pool B.

Consistent with Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), an amendment to the license (including the technical specifications) must fully describe the changes requested, and follow, as far as applicable, the form prescribed for original applications.

Section 50.34 of 10 CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.

The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staff's acceptance review of this request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review and make an independent assessment regarding the acceptability of the proposed change. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.

The NRC staff has reviewed your application and concluded that the information delineated below is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed amendment in terms of regulatory requirements and the protection of public health and safety and the environment.

C. Burton -2 Please address the following:

1) Potential Error in TS Design Features, Figure 5.6-3:

There appears to be an error in the equation included in Figure 5.6-3 of the TS Design Features section. Please correct, if applicable.

2) Potential Error in Table 1 of Holtec Report No. HI-2043321 , Revision 4: "Criticality Safety Analyses of BWR [Boiling Water Reactor] Fuel Without Credit for Boraflex in the Racks at the Harris Nuclear Power Station" (Proprietary):

There appears to be an error in Table 1 of HI-2043321 for the value of "Maximum Keff" corresponding to the 2 percent enrichment case. Please correct, if applicable.

3) Criticality Model:

a) Figure 3 of HI-2043321 shows the calculational model of a typical storage cell.

Is this model an approximation of the actual configuration? If so, please show the impact of the approximation on the calculated reactivity.

b) Consider a four assembly configuration where each assembly is loaded closest to the common corner. Please explain how this configuration was modeled with a single cell model.

4) Reference Fuel Design:

a) Please explain how the reactivity values in Table 7 of HI-2043321 were calculated. Are they based on CASMO or MCNP calculations? State the assumed depletion parameters (void history, axial burnup distribution, burnable absorbers, control history) and demonstrate that the assumed parameters bound the actual operating history of these fuel assemblies.

b) The application does not provide sufficient information to justify the use of GE13 fuel as the reference design when GE3 and GE4 show higher reactivity values.

Please provide quantitative evidence showing that GE3 and GE4 assemblies residing in the spent fuel pool are bounded by the reference design. Consider the actual enrichments, burnups, and cooling times for the GE3 and GE4 assemblies.

c) The application states that a fuel enrichment of 4.6 percent and burnups between 35,000 and 42,500 MWD/MTU were assumed for the reactivity calculations in Table 7 of HI-2043321. Please demonstrate that the bounding design has been identified considering lower fuel enrichments and lower burnup.

C. Burton -3

5) Axial Burnup Distribution:

The application states, "based on the level of conservatism inherent in choosing the axial burnup distribution in the manner described above it is not necessary to confirm that the axial burnup distributions of individual assemblies are bounded by the assumed axial bumup distribution."

Please explain what is meant by "inherent conservatism."

6) Boraflex Monitoring Program:

In the application, the licensee is proposing to no longer credit Boraflex for criticality in HNP's BWR Boraflex storage racks in Spent Fuel Pools A and B. Currently, the licensee is committed to periodic sampling of the Boraflex in the spent fuel pool as stated in their October 24, 1996, response to Generic Letter 96-04, "Boraflex Degradation in the Spent Fuel Pool Storage Racks." However, it is not clear in the submittal whether the licensee is intending to continue the Boraflex Monitoring Program.

Please clarify whether the existing Boraflex Monitoring Program will continue to be implemented.

In order to make the application complete, the NRC staff requests that HNP supplement the amendment request to address the information requested above. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staff's request is not received, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC staff will cease its review activities associated with the application. Conversely, if the amendment is subsequently accepted for review, you will be advised of any further information needed to support the NRC staff's detailed technical review by separate correspondence.

The information requested and the associated time frame outlined in this letter were discussed with Dave Baska, Kara Stacy, and other members of your staff on December 17,2008. If you have any questions, please contact me at (301) 415-3178.

Marlayna Vaaler, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-400 cc: Distribution via ListServ

ML090210011 NRR-106 OFFICE LPL2-2/PM LPL2-2/LA LPL2-2/BC NAME MVaaler CSoia TBoyce DATE 1/22/09 1/22/09 1/27/09