ML13241A510
| ML13241A510 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 08/29/2013 |
| From: | Mozafari B Plant Licensing Branch III |
| To: | Pacilio M Exelon Generation Co |
| Mozafari B | |
| References | |
| TAC MF2489, TAC MF2490 | |
| Download: ML13241A510 (4) | |
Text
August 29, 2013 Mr. Michael J. Pacilio Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO)
Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
QUAD CITIES NUCLEAR POWER STATION, UNITS 1 and 2 - ACCEPTANCE REVIEW - UNACCEPTABLE WITH OPPORTUNITY TO SUPPLEMENT (TAC NOS. MF2489 AND MF2490)
Dear Mr. Pacilio:
By letter dated July 16, 2013 (Agencywide Documents Access and Management System Accession No. ML13199A037), Exelon Generation Company, LLC (EGC) submitted a license amendment request for the Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2.
The proposed amendment would modify the Technical Specifications (TSs) to include the use of neutron absorbing spent fuel pool (SFP) rack inserts (i.e., NETCO-SNAP-IN rack inserts) for the purpose of criticality control in the SFPs at QCNPS. This change is being requested due to degradation of the Boraflex neutron absorbing material, currently being used in the QCNPS SFPs. The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this amendment 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.
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.
Consistent with Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), an amendment to the license (including the TSs) must fully describe the changes requested, and following 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 NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter 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.
M. Pacilio In order to make the application complete, the NRC staff requests that EGC supplement the application to address the information requested in the enclosure by September 19, 2013, which will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staffs request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its review activities associated with the application. If the application is subsequently accepted for review, you will be advised of any further information needed to support the staffs detailed technical review by separate correspondence.
The information requested and associated time frame in this letter was discussed with Ken Nicely and members of your staff on August 27, 2013.
If you have any questions, please contact me, at (301) 415-2020.
Sincerely,
/RA/
Brenda Mozafari, Senior Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-254 and 50-265
Enclosure:
Supplemental for Information Request cc w/encl: Distribution via Listserv
- By E-Mail OFFICE LPL3-2/PM LPL3-2/LA DSS/SRXB LPL3-2/BC(A)
LPL3-2/PM NAME BMozafari SRohrer CJackson
- JWiebe BMozafari DATE 08/29/2013 08/29/2013 08/27/2013 08/29/2013 08/29/2013
ENCLOSURE REQUEST FOR SUPPLEMENTAL INFORMATION EXELON GENERATION COMPANY, LLC QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NUMBERS 50-254 AND 50-265 The licensee has performed the nuclear criticality safety analysis using an insert 10B areal density of 0.0116 gm/cm2. As stated in the application, during the manufacturing process an uncertainty is applied to the areal density measurements to provide a 95 percent probability at a 95 percent confidence level (95/95) that those measurements meet or exceed 0.0116 gm/cm2 areal density. While this provides 95/95 that a given batch of material meets or exceeds 0.0116 gm/cm2 areal density, it also means that there is a 5 percent probability at a 95 percent confidence level that the measured 10B areal density of a given batch is actually below 0.0116 gm/cm2. Based on this approach one would expect 5 percent of the batches to have a 10B areal density below 0.0116 gm/cm2. Given the number of batches of material expected to complete the installation of inserts there would be potentially hundreds of inserts below the 10B areal density used in nuclear criticality safety analysis. Since criticality is a local phenomenon, collocation of the inserts from a batch with a 10B areal density below 0.0116 gm/cm2 would result in a higher keff than estimated in the nuclear criticality safety analysis. In this regard the NRC staff requests the following additional information:
How is the licensee controlling the installation of the inserts to ensure that none with a potential 10B areal density less than 0.0116 gm/cm2 are collocated?
How are the proposed Technical Specifications and material surveillances applicable, given that the actual as-built areal density of numerous inserts is potentially below the minimum acceptable standard of 0.0116 gm/cm2?
Section 2.7 of Holtec HI-2124245 R2 is essentially establishing a methodology for analyzing future fuel assemblies. However, the description of that methodology is incomplete. In this regard the NRC staff requests the licensee to provide full and complete description of the methodology including all analyses performed to support the methodology, assumptions both implicit and explicit, detailed implementation guidance, and all limitations and conditions.
Additionally, the staff have also noted issues with the proprietary markings in the submittal.
Additionally, the NRC staff has noted numerous instances where material that is marked as proprietary does not meet the 10 CFR 2.390 criteria for withholding or are not properly marked in accordance with 10 CFR 2.390. For example the submittal claims that Holtec HI-2104790 is proprietary in its entirety. However, most of what is in the document is essentially verbatim out of a publicly available NRC NUREG/CR. Therefore it does not meet 10 CFR 2.390 criteria (b)(4)(iv) or (b)(4)(v). Additionally, the proprietary version of HI-2124245 R2 does not have any proprietary markings on the text to indicate which portions are to be withheld and which are not met 10 CFR 2.390 criteria (b)(4)(iv) or (b)(4)(v). Additionally, the proprietary version of HI-2124245 R2 does not have any proprietary markings on the text to indicate which portions are to be withheld and which are not.