HNP-09-081, Response to Request for Additional Information Regarding Amendment to Remove Credit for Boraflex in the Boiling Water Reactor Spent Fuel Pool Storage Racks

Response to Request for Additional Information Regarding Amendment to Remove Credit for Boraflex in the Boiling Water Reactor Spent Fuel Pool Storage Racks

ML092310549
Person / Time
Site:	Harris
Issue date:	08/12/2009
From:	Burton C Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
HNP-09-081, TAC ME0012
Download: ML092310549 (4)

Text

C Progress Energy Christopher L.Burton Vice President Harris Nuclear Plant Progress Energy Carolinas, Inc.

Serial: HNP-09-081 AUG 12 2M09 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/RENEWED LICENSE NO. NPF-63 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING AMENDMENT TO REMOVE CREDIT FOR BORAFLEX IN THE BOILING WATER REACTOR SPENT FUEL POOL STORAGE RACKS (TAC NO. ME0012)

References:

1. Letter from C. L. Burton to the Nuclear Regulatory Commission (Serial:

HNP-08-075), "Technical Specifications 5.6.1.3.a and 5.6.1.3.b -

Incorporation of Updated Criticality Analyses to Reflect Removal of Credit For Boraflex in BWR Spent Fuel Pool Storage Racks," dated September 29, 2008 (ML082800400)

2. Letter from C. L. Burton to the Nuclear Regulatory Commission (Serial:

HNP-09-007), "Supplement to Technical Specifications 5.6.1.3.a and 5.6.1.3.b - Incorporation of Updated Criticality Analyses to Reflect Removal of Credit For Boraflex in BWR Spent Fuel Pool Storage Racks," dated January 16, 2009 (ML090230341)

3. Letter from M. Vaaler, Nuclear Regulatory Commission, to C. L. Burton, "Shearon Harris Nuclear Power Plant, Unit 1 - Request for Additional Information Regarding Amendment to Remove Credit for Boraflex in the Boiling Water Reactor Spent Fuel Pool Storage Racks (TAC NO.

ME0012)," dated June 5, 2009 (ML091270238)

Ladies and Gentlemen:

On June 5, 2009, the Harris Nuclear Plant (HNP) received a request from the NRC (Reference 3) for additional information needed to facilitate the review of the License Amendment Request to revise HNP Technical Specifications to incorporate an updated criticality analyses reflecting the removal of credit for Boraflex in BWR spent fuel pool storage racks. This original request was submitted as HNP-08-075 (Reference 1) and supplemented via HNP-09-007 (Reference 2).

P.O.

Box 165 pýi New Hill, NC 27562 01(z<

T> 919.362.2502 F> 919.362.2095

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Serial: HNP-09-081 Page 2 Per discussions with Marlayna Vaaler, NRC Project Manager for HNP, HNP's responses to these questions will be provided in two parts. Submittal to the NRC of the requested additional information needed for question 8 is to be provided by August 12, 2009, and submittal of the remaining responses will be provided in September 2009. Accordingly, the Enclosure to this letter provides the requested additional information for question 8.

This document contains no regulatory commitments.

Please refer any questions regarding this submittal to Mr. Dave Corlett, Supervisor -

Licensing/Regulatory Programs, at (919) 362-3137.

I declare under penalty of perjury that the foregoing is true and correct. Executed on AUG 12 7!909 Sincerely, Christopher L. Burton Vice President Harris Nuclear Plant CLB/kms Enclosure cc:

Mr. J. D. Austin, NRC Sr. Resident Inspector, HNP Ms. B. 0. Hall, N.C. DENR Section Chief Mr. L. A. Reyes, NRC Regional Administrator, Region II Ms. M. G. Vaaler, NRC Project Manager, HNP

Enclosure to SERIAL: HNP-09-081 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/RENEWED LICENSE NO. NPF-63 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING AMENDMENT TO REMOVE CREDIT FOR BORAFLEX IN BWR SPENT FUEL POOL STORAGE RACKS Summary Carolina Power & Light Company, now doing business as Progress Energy Carolinas, Inc.,

(PEC) (licensee) submitted a license amendment request to modify Harris Nuclear Plant's (HNP)

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 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.

The U.S. Nuclear Regulatory Commission staff determined that it needed additional information in order to complete its review.

8. Since the Boraflex monitoringprogramwill be discontinuedas a result of this proposed license amendment request,please explain how HNP will be able to identify and mitigate any degradationof the Boraflex that may impede other plant operations. Examples may include excessive silica levels impacting the spentfuel pool chemistry or an unforeseen damage mechanism to the Boraflex cladding that may impact safe fuel handling.

Response

After the Boraflex monitoring program is discontinued, several other methods that currently allow HNP to monitor Boraflex degradation via silica sampling for indications that could result in the potential to impede other plant operations will remain in place. HNP's sampling program is contained in CRC-001, HNP Environmental and Chemistry Sampling and Analysis Program.

The basis for primary and secondary system chemistry control at HNP is the System Chemistry Strategic Plan (PLP-715), which details the chemistry plans that meet the guidelines of NEI 97-06, Steam Generator Program Guidelines, NEI 03-08, Guidelines for the Management of Materials Issues, and the EPRI Chemistry Guidelines. In accordance with this guidance, HNP currently monitors the amounts of silica, an indicator of degraded Boraflex, in various systems as follows:

• Spent Fuel Pools: Sampled on a monthly basis as part of the HNP Environmental and Chemistry Sampling and Analysis Program (CRC-001)

• Reactor Coolant System: Sampled weekly as required to assess potential silica deposition on fuel cladding surfaces in accordance with EPRI PWR Primary Chemistry Page 1 of 2

Enclosure to SERIAL: HNP-09-081 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/RENEWED LICENSE NO. NPF-63 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING AMENDMENT TO REMOVE CREDIT FOR BORAFLEX IN BWR SPENT FUEL POOL STORAGE RACKS Guidelines Table 3-4 for reactor critical reactor coolant system power operation diagnostic parameters (PLP-715)

Reactor Make-up source water: Sampled quarterly with a focus on those hardness elements which may impact fuel performance in accordance with EPRI PWR Primary Chemistry Guidelines Table 3-5 for all modes diagnostic parameters (PLP-715) 8a. (via email)

In the HNP license renewal application, the licensee included an Aging Management Program (AMP) element regardinga Boraflex MonitoringProgram. Does HNP still intend to implement this program in light of the proposedchange?

Response

No, the Aging Management Program element regarding the Boraflex Monitoring Program as contained in the HNP license renewal application will also be removed once the current Boraflex Monitoring Program is discontinued. As discussed in question 8 response (above) there are other monitoring programs currently in place at HNP to detect excessive silica levels which could have a potential to impede other plant operations. These will remain in place after the current Boraflex Monitoring Program is discontinued.

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