ML12332A365

Summary of Meeting with Luminant Generation Company LLC, to Discuss License Amendment Request for Approval of Revised Spent Fuel Criticality Analysis to Update Comanche Peak, Units 1 and 2, Technical Specifications (TAC Nos. ME8896-ME8897)

ML12332A365
Person / Time
Site:	Comanche Peak
Issue date:	12/18/2012
From:	Balwant Singal Plant Licensing Branch IV
To:
Singal B
References
TAC ME8896, TAC ME8897
Download: ML12332A365 (5)

Text

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LICENSEE: Luminant Generation Company LLC FACILITY: Comanche Peak Nuclear Power Plant, Units 1 and 2

SUMMARY

OF NOVEMBER 20, 2012, PRE-SUBMITTAL PUBLIC MEETING WITH LUMINANT GENERATION COMPANY LLC TO DISCUSS THE PROPOSED LICENSE AMENDMENT REQUEST FOR APPROVAL OF THE REVISED SPENT FUEL POOL CRITICALITY ANALYSIS FOR COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 (TAC NOS. ME8896 AND ME8897)

On November 20,2012, a public meeting was held between the U.S. Nuclear Regulatory Commission (NRC), and representatives of Luminant Generation Company LLC (Luminant, the licensee), at NRC Headquarters, Rockville, Maryland. The meeting notice and agenda, dated November 5, 2012, is located in the Agencywide Documents Access and Management System (ADAMS) under Accession No. ML12299A410. The purpose of the meeting was to discuss the proposed license amendment request (LAR) by the licensee for revision of Technical Specification (TS) 3.7.17, "Spent Fuel Assembly Storage," TS 3.7.16, "Fuel Storage Pool Boron Concentration," and TS 4.3, "Fuel Storage," at Comanche Peak Nuclear Power Plant, Units 1 and 2.

A list of meeting attendees is provided in Enclosure 1 to this meeting summary.

Meeting Summary The discussion covered the following key topics:

• To provide the NRC an overview of the upcoming spent fuel pool LAR, which will supplement TS 3.7.17 to address fuel discharged from post-uprate conditions and implement additional controls, which is intended to provide additional margin.

• A subsequent LAR that will satisfy the commitment to prepare and submit aLAR, as specified in Confirmatory Action Letter 4-12-004 dated October 22, 2012 (ADAMS Accession No. ML12296A937).

A copy of the meeting materials/handouts is located at ADAMS Accession No. ML12328A125.

Results of Discussions

1. The licensee provided the schedules for submitting the LARs related to spent fuel pool criticality as follows:

• LAR to revise TS 3.7.17, TS 3.7.16, and TS 4.3 in January 2013.

- 2

• LAR to revise the criticality analysis in March 2013.

2. Concerns and challenges raised by the NRC staff include:

• A proposed continuation of administrative controls is problematic when TS changes appear warranted.

• A need for the analysis assumptions and justifications for design calculations to be clearly described in the LAR.

• The impacts of power uprate on temperature profiles need to be considered.

Interim Staff Guidance (DSS-ISG-201 0-01, "Staff Guidance Regarding the Nuclear Criticality Safety Analysis of Spent Fuel Pools" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML110620086) referenced in Information Notice 2011-03, "Nonconservative Criticality Safety Analyses for Fuel Storage" (ADAMS Accession No. ML103090055) provides an approach acceptable to the NRC staff for developing the analysis of record.

• Modifying the Final Safety Analysis Report (FSAR) may not be sufficient to provide the controls necessary to meet the regulations. Likewise, merely referencing the FSAR in the TSs may be a challenge for the NRC staff's review and approval.

• The proposed LAR should identify the conservatisms in the analysis and the available margin. Non-conservatisms should be quantified.

• The NRC staff expects the licensee's submittal to fully address the questions of no significant hazards consideration determination.

3. The NRC staff expressed concern that the proposed LAR submittal approach may be challenging because it appears to be very complicated, continues to rely heavily rely on administrative controls, and may not fully address all the issues in the ISG.

No Public Meeting Feedback Forms were received for this meeting.

-3 Please direct any inquiries to me at (301) 415-3016, or balwant.singal@nrc.gov.

Sincerely,

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Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosure:

List of Attendees cc w/encl: Distribution via Listserv

LIST OF ATTENDEES NOVEMBER 20,2012, MEETING WITH LUMINANT GENERATION COMPANY LLC PRE-SUBMITTAL MEETING REGARDING PROPOSED LICENSE AMENDMENT REQUESTS FOR APPROVAL OF REVISED SPENT FUEL POOL CRITICALITY ANALYSIS AND ASSOCIATED TECHNICAL SPECIFICATION CAHNGES COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446 NAME TITLE ORGANIZAliON KentWood Team Leader U.S. Nuclear Regulatory Commission (NRC)

Chris Jackson Branch Chief NRC GerryWaig* Senior Reactor Systems Engineer NRC Jason Dykert* Reactor Engineer NRC (Region IV)

Wayne Walker* Branch Chief NRC (Region IV)

Emma Wong Chemical Engineer NRC

• N. Kalyanam Project Manager NRC Michael Markley Branch Chief NRC Tim Hope Manager, Nuclear Licensing Luminant Generation Company LLC (Luminant)

Jimmy Seawright Consulting Engineer, Regulatory Luminant Affairs Matthew Weeks Core Performance, Engineering Luminant Manager Cody Lemons Core Performance Engineer Luminant Kris Cummings Manager, Fuel Engineering Westinghouse +

Licensing

+

Blanco Andrew Criticality Analyst Westinghouse Ben Mays VP, Nuclear Engineering Luminant

• Participated via phone

+ Represented Luminant Enclosure

ML12332A365 *via email M NRRlDORULPL4/LA NRR/DSS/SRXB/BC JBurkhardt CJackson*

12/6/12 12/13/12 NAME RElliott* GKulesa* MMarkley DATE 12/10/12 12/11/12 12/18/12