RS-14-329, Additional Information Regarding License Amendment Request Associated with Use of Neutron Absorbing Inserts in Spent Fuel Pool Storage Racks

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Additional Information Regarding License Amendment Request Associated with Use of Neutron Absorbing Inserts in Spent Fuel Pool Storage Racks
ML14317A753
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 11/11/2014
From: Simpson P
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-14-329
Download: ML14317A753 (3)


Text

4300 Winfield Road Warrenville. IL 60555 Exelon Generation 630 657 2000 Office RS-14-329 November 11, 2014 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Additional Information Regarding License Amendment Request Associated with Use of Neutron Absorbing Inserts in Spent Fuel Pool Storage Racks

Reference:

1. Letter from D. M. Gullatt (Exelon Generation Company, LLC) to U.S. NRC, "License Amendment Request - Use of Neutron Absorbing Inserts in Units 1 and 2 Spent Fuel Pool Storage Racks, 11 dated July 16, 2013
2. Letter from P.R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "Additional Information Regarding License Amendment Request Associated with Use of Neutron Absorbing Inserts in Spent Fuel Pool Storage Racks,"

dated August 12, 2014 In Reference 1, Exelon Generation Company, LLC (EGC) requested a license amendment to modify the Technical Specifications (TS) to include the use of neutron absorbing spent fuel pool rack inserts (i.e., NETCO-SNAP-IN rack inserts) for the purpose of criticality control in the spent fuel pools (SFPs) at Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2. This change was requested due to the degradation of the Boraflex neutron absorbing material, currently being used in the QCNPS SFPs.

On November 10, 2014, a public meeting between the NRC and EGC was held to discuss the appropriate means to integrate the rack insert surveillance program into the QCNPS licensing basis. Specifically, the NRC discussed performance objectives of the program that must be met and provided the bases to support the need to escalate certain elements of the proposed rack insert surveillance program discussed in Reference 1, as modified by Reference 2, from regulatory commitments into obligations. During the meeting, the NRC also discussed their recognition that some elements of the proposed rack insert surveillance program could be changed in the future using the appropriate change control mechanisms (e.g., 10 CFR 50.59 and*EGC's Commitment Management Process); however, the surveillance program performance objectives being escalated into obligations cannot be changed without prior NRC approval. At the conclusion of the meeting, EGC agreed to submit a letter to the NRC that incorporates EGC's comments on the NRC's proposed performance objectives, as discussed and clarified during the meeting, and that documents EGC's acceptance and understanding of the NRC's plans to issue a license condition.

November 11, 2014 U.S. Nuclear Regulatory Commission Page 2 Accordingly, EGC understands that the NRC plans to issue a license condition that will require the following rack insert surveillance program performance objectives to be met.

1. Ensure that coupon evaluations of Boron-1 O areal densities are performed by a qualified laboratory;
2. Ensure that insert evaluations are performed to verify that any service wear is within expected parameters;
3. Ensure that the evaluations are performed at intervals not to exceed four years for coupon Boron-10 areal density, and 10 years for insert service wear;
4. Ensure that if any inserts are identified as potentially failing the minimum certified Boron-10 areal density criterion, based on correlation of the coupon evaluation or insert service wear evaluation results to inserts, or other abnormal indications, EGC will take affected inserts out of service until it can be positively demonstrated that the minimum certified Boron-1 O areal density criterion (0.0116 g/cm2) is met for each insert; and,
5. Submit a report to the NRC, within 90 days following completion of evaluations associated with Item 4 above, that describes the testing results, assessments performed, and interim and long-term corrective actions for abnormal indications.

The proposed license condition discussed above impacts regulatory commitments previously made in Reference 1. As such, a revised summary of regulatory commitments is attached.

These regulatory commitments supersede those made in Reference 1 in their entirety.

EGC has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRC in Attachment 1 of Reference 1. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

As stated in Reference 1, EGC requests approval of the proposed amendment by December 31, 2014. Should you have any questions concerning this letter, please contact Mr. Kenneth M. Nicely at (630) 657-2803.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 11th day of November 2014.

RfGR Patrick R. Simpson Manager - Licensing

Attachment:

Summary of Regulatory Commitments cc:

NRC Regional Administrator, Region Ill NRC Senior Resident Inspector-Quad Cities Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT Summary of Regulatory Commitments The following list identifies those actions committed to by Exelon Generation Company, LLC, (EGC) for Quad Cities Nuclear Power Station. Any other actions discussed in the submittal represent intended or planned actions by EGC, are described only for information, and are not regulatory commitments.

COMMITMENT TYPE COMMITTED DATE ONE.. TIME PROGRAMMATIC OR "OUTAGE" ACTION (YES/NO)

COMMITMENT (YES/NO)

EGC will update the UFSAR to Upon implementation Yes No describe the Rio-Tinto Alcan of the proposed Composite Surveillance Program as change described in Section 3.9 of to EGC's letter dated July 16, 2013, as modified by to EGC's letter dated August 12, 2014.

The k-infinity limitations will be Upon implementation No Yes incorporated into reload design of the proposed documents and SFP criticality change compliance procedures.

The k-infinity limitations will be Upon implementation Yes No reflected in Section 9.1.2 of the of the proposed UFSAR.

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