ML14058A089

Request for Additional Information Round 3, Amendment Request to Revise TS 3.7.16, Fuel Storage Pool Boron Concentration, TS 3.7.17, Spent Fuel Assembly Storage, and TS 5.5, Programs and Manuals

ML14058A089
Person / Time
Site:	Comanche Peak
Issue date:	02/27/2014
From:	Balwant Singal Plant Licensing Branch IV
To:	Flores R Luminant Generation Co
Singal B
References
TAC MF1365, TAC MF1366
Download: ML14058A089 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 27, 2014 Mr. Rafael Flores Senior Vice President and Chief Nuclear Officer Attention: Regulatory Affairs Luminant Generation Company LLC P.O. Box 1002 Glen Rose, TX 76043

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING REVISED TECHNICAL SPECIFICATIONS 3.7.16, "FUEL STORAGE POOL BORON CONCENTRATION,"

3. 7.17, "SPENT FUEL ASSEMBLY STORAGE," 4.3, "FUEL STORAGE," AND 5.5, "PROGRAMS AND MANUALS" (TAC NOS. MF1365 AND MF1366)

Dear Mr. Flores:

By letter dated March 28, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13095A023), as supplemented by letters dated July 16, October 22, November 26, and December 17, 2013(ADAMS Accession Nos. ML13205A056, ML13309A026, ML13346A175, and ML14016A124, respectively), and January 16, 2014 (ADAMS Accession No. not available at this time)) Luminant Generation Company LLC (the licensee) submitted a license amendment request for revision to the Facility Operating License Nos. NPF-87 and NPF-89 for Comanche Peak Nuclear Power Plant (CPNPP), Units 1 and 2, respectively. The amendment also seeks revision of the CPNPP, Units 1 and 2, Technical Specifications based on an updated criticality analysis methodology for the spent fuel pool.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the information provided in your application and determined that additional information is required in order to complete its review. A draft copy of the enclosed request for additional information (RAI) was provided to Mr. Jimmy Seawright of your staff via e-mail on February 12, 2014. An RAI clarification call was held on February 20, 2014. The licensee agreed to provide the RAI response within 60 days from the date of the call.

R. Flores If you have any questions, please contact me at 301-415-3016 or balwant.singal@nrc.gov.

Sincerely,

-Bo<:.O. ~~ ~ ~-?---

Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosure:

Request for Additional Information cc w/enclosure: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION REGARDING REVISED TECHNICAL SPECIFICATIONS 3.7.16, "FUEL STORAGE POOL BORON CONCENTRATION," 3. 7.17, "SPENT FUEL ASSEMBLY STORAGE,"

4.3, "FUEL STORAGE," AND 5.5, "PROGRAMS AND MANUALS" LUMINANT GENERATION COMPANY LLC COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446 By letter dated March 28, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13095A023), as supplemented by letters dated July 16, October 22, November 26, and December 17, 2013 (ADAMS Accession Nos. ML13205A056, ML13309A026, ML13346A175, and ML14016A124, respectively), and January 16, 2014 (ADAMS Accession No. not available at this time)) Luminant Generation Company LLC (the licensee) submitted a license amendment request for revision to the Facility Operating License Nos. NPF-87 and NPF-89 for Comanche Peak Nuclear Power Plant (CPNPP), Units 1 and 2, respectively. The amendment also seeks revision of the CPNPP, Units 1 and 2, Technical Specifications based on an updated criticality analysis methodology for the spent fuel pool (SFP).

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the information provided in your application and determined that the following additional information is required in order to complete its review.

Request for Additional Information {RAI)

1. WCAP-17728-P (Enclosure 2 to letter dated March 28, 2013) indicates that periodic boundary conditions are used for all storage array models in the x-y plane including Array 11-A. The NRC staff believes that using a periodic boundary condition for the x-direction would be inappropriate as it would be simulating a water/wall boundary condition for Array 11-B which is required to border Array 11-A. Please describe the boundary conditions were used in the Array II-A analysis for normal, accident, and interface conditions.

2. Please describe how the interface conditions were modeled for all of the Region I and Region II interface calculations. Please also describe how many of each array were modeled in the x-y plane and what boundary conditions were used.

Enclosure

3. It appears that the methodology used in WCAP-17728-P for addressing the interface between rack designs, between storage arrays within a rack design, and within a storage array itself are not consistent with the guidance in Interim Staff Guidance (ISG) DSS ISG-201 0-01, "Staff Guidance Regarding the Nuclear Criticality Safety Analysis for Spent Fuel Pools" (ADAMS Accession No. ML110620086), which states, in part, that Absent a determination of a set of biases and uncertainties specifically for the combined interface model, use of the maximum biases and uncertainties from the individual storage configurations should be acceptable in determining whether the keff of the combined interface model meets the regulatory requirements.

Please either revise the analysis to be consistent with DSS ISG-2010-01 or provide the justification for the methodology used in WCAP-17728-P, including the results of the analyses performed to support that methodology. Also, please include the analysis results for the Array II-A and Array 1-A interface calculation.

4. WCAP-17728-P uses the FIGHTH code in the criticality safety analysis to determine the fuel assembly axial and radial temperature distribution used in the depletion analysis.

Please justify the use of FIGHTH for this application and explicitly explain how fuel thermal conductivity degradation is addressed. If FIGHTH is NRC-approved for this application, please cite the reference and address any limitations.

ML14058A089 *via email OFFICE NRR/DORLILPL4-1/PM NRR/DORL/LPL4-1/LA* NRR/DSS/SRXB/BC NAME BSingal JBurkhardt CJackson DATE 2/27/14 2/27/14 2/27/14 OFFICE NRR/DORLILPL4-1/BC NRR/DORLILPL4-1/PM NAME MMarkley (Flyon for) BSingal DATE 2/27/14 2/27/14