CP-201400619, License Amendment Request (LAR) 13.01, Spent Fuel Pool Criticality Analysis, Supplemental Information to Requests for Additional Information
| ML14136A027 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/01/2014 |
| From: | Flores R, Madden F Luminant Generation Co, Luminant Power |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CP-201400619, TAC MF1365, TAC MF1366, TXX-14061 | |
| Download: ML14136A027 (3) | |
Text
Rafael Flores Senior Vice President
& Chief Nuclear Officer rafael.flores@Luminant.com Luminant Luminant Power P 0 Box 1002 6322 North FM 56 Glen Rose, TX 76043 T 254 897 5590 C 817 559 0403 F 254 897 6652 REF:
10CFR50.90 CP-201400619 TXX-14061 May 1, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
COMANCHE PEAK NUCLEAR POWER PLANT (CPNPP)
DOCKET NOS. 50-445 AND 50-446 LICENSE AMENDMENT REQUEST (LAR) 13-01 SPENT FUEL POOL CRITICALITY ANALYSIS, SUPPLEMENTAL INFORMATION TO REQUESTS FOR ADDITIONAL INFORMATION (TAC NOS. MF1365 AND MF1366)
REFERENCE:
- 1.
Letter logged TXX-13045, dated March 28, 2013, License Amendment Request (LAR) 13-01, Revision to 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" (ML13095A023)
- 2.
Letter logged TXX-13109, dated July 16, 2013, "Supplemental Information supporting LAR 13-01, Spent Fuel Pool Criticality Analysis" (ML13205A056)
- 3.
Letter logged TXX-13169, dated November 26, 2013, RE: CPNPP response to Requests for Additional Information for LAR 13-01, Spent Fuel Pool Criticality Analysis
- 4.
Letter logged TXX-13182, dated December 17, 2013, RE: CPNPP response to Requests for Additional Information for LAR 13-01, Spent Fuel Pool Criticality Analysis
- 5.
Letter logged TXX-14008, dated January 16, 2014, RE: CPNPP response to Requests for Additional Information for LAR 13-01, Spent Fuel Pool Criticality Analysis
- 6.
Letter logged TXX-14053, dated April 17, 2014, RE: CPNPP response to Requests for Additional Information for LAR 13-01, Spent Fuel Pool Criticality Analysis
- 7.
Phone call on April 29, 2014, between the NRC and Luninant Power, RE: Supplemental information to letter logged TXX-14053 for License Amendment Request 13-01
Dear Sir or Madam:
In March 2013, Luminant Generation Company LLC (Luminant Power) submitted a License Amendment Request (LAR) 13-01 (Reference 1, as supplemented by Reference 2 and the response to Requests for Additional Information in References 3, 4, 5, and 6) to the NRC for Facility Operating License Nos. NPF-87 and NPF-89 for Comanche Peak Nuclear Power Plant (CPNPP), Units 1 and 2, respectively. This LAR proposes a change to the CPNPP, Units 1 and 2, Technical Specifications based on an updated criticality analysis methodology for the spent fuel pools.
Per Reference 7, the NRC staff has requested information to supplement Reference 6, be submitted in order to complete its review. The Attachment to this letter provides the supplemental information to Luminant Power's response to Requests for Additional Infornation (RAIs) in Reference 6.
A member of the STARS Alliance Callaway - Comanche Peak - Diablo Canyon. Palo Verde
- Wolf Creek
U. S. Nuclear Regulatory Commission TXX-14061 Page 2 of 2 05/0112014 In accordance with 10CFR50.91(b), Luminant Power is providing the State of Texas with a copy of this proposed amendment. of Reference 1, Description and Assessment, which addresses the no significance hazards consideration standards set forth in 10CFR50.92, remains valid and does not require change.
This communication contains the following new commitment regarding CPNPP Units 1 and 2.
Commitment No.
4844167 Description Following implementation of the PETRIFIED software, Luminant Power will operationally verify (independent of PETRIFIED calculations) the TS 3.7.17 categorization calculations for fuel discharged from Unit 2 Cycle 14 and Unit 1 Cycle 17 prior to storing these assemblies in Region II. CPNPP will further operationally verify (independent of PETRIFIED) fuel movement plans which impact Region II during 2014, to ensure the allowed configurations of TS 3.7.17 are maintained. Fuel movement plans which impact Region II includes movement of fuel into Region II as well as fuel movement within Region II (reconfiguration). These operational verification activities will be performed by an individual independent of the software developer and the developer of the initial PETRIFIED test plan, but maintains at least the same level of qualification.
Should you have any questions, please contact Mr. J. D. Seawright at (254) 897-0140.
I state under penalty of perjury that the foregoing is true and correct.
Executed on May 1, 2014.
Sincerely, Luminant Generation Company LLC Rafael Floaes By:
/
.//Fred W. Madden Director, External Affairs Attachments:
Supplemental Information to Luminant Power's response to Requests for Additional Information (RAIs) c -
Marc L. Dapas, Region IV Balwant K. Singal, NRR Resident Inspectors, Comanche Peak Mr. Robert Free Environmental Monitoring & Emergency Response Manager Texas Department of State Health Services Mail Code 1986 P. 0. Box 149347 Austin, Texas 78714-9347
Attachment to TXX-14061 Page 1 of 1 Supplemental Information to Luminant Power's response to Requests for Additional Information (RAIs)
During a phone call between the NRC and Luminant Power on April 29, 2014, the NRC staff has requested supplemental information to support Luminant Power's response to RAIs. The requested supplemental information is described below:
"In response to RAI 3.c of letter dated April 17, 2014, Attachment 1, the licensee stated that "it is possible that an undetected software error could result in a violation of the TS 3.7.17 limitations, which would be considered a misload accident." The licensee also stated in Enclosure 1, Section 2 of LAR 13-01, that "fuel handling errors which result in a misload event will be detected in a timely fashion due to required post-fuel move reviews of the storage configuration pattern." The staff is concerned that the post-fuel movement visual verifications may not be enough to detect an error in the PETRIFIED software. Since the PETRIFIED software has no operational history, the staff wants to know if the licensee is planning on performing independent verification of the software outputs, as a compensatory measure, during actual refueling outages."
CPNPP Response:
CPNPP has performed extensive testing of the PETRIFIED software as described in letter logged TXX-14053 (Reference 6). Included in the testing was a verification of proper classification of the entire contents of the CPNPP spent fuel, including the contents of both Region I and Region II of both spent fuel pools 1 and 2 (over 2,300 fuel assemblies). At the time of testing Unit 2 Cycle 14 was in operation, therefore this verification did not include discharge fuel from Unit 2 Cycle 14. The testing also analyzed the current configurations of both spent fuel pools, in addition to multiple test configurations, and concluded that the software correctly identified the proposed TS 3.7.17 acceptable configurations and properly identified invalid configurations. In addition to the above software testing, CPNPP will perform the operational verification described below for all Region II fuel movement in 2014, which is expected to involve approximately 700-800 fuel movement steps. The action described below ensures TS 3.7.17 compliance while providing independent verifications of the PETRIFIED software with operational experience from two refueling cycles.
Following implementation of the PETRIFIED software, Luminant Power will operationally verify (independent of PETRIFIED calculations) the TS 3.7.17 categorization calculations for fuel discharged from Unit 2 Cycle 14 and Unit 1 Cycle 17 prior to storing these assemblies in Region II. CPNPP will further operationally verify (independent of PETRIFIED) fuel movement plans which impact Region II during 2014, to ensure the allowed configurations of TS 3.7.17 are maintained. Fuel movement plans which impact Region II includes movement of fuel into Region II as well as fuel movement within Region II (reconfiguration). These operational verification activities will be performed by an individual independent of the software developer and the developer of the initial PETRIFIED test plan, but maintains at least the same level of qualification.