ML17285B196
| ML17285B196 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, Nine Mile Point, Clinton, FitzPatrick, Crane  |
| Issue date: | 10/27/2017 |
| From: | Blake Purnell Plant Licensing Branch III |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| Purnell B | |
| References | |
| CAC MF9414, CAC MF9428, CAC MF9429, CAC MF9440, CAC MF9448, CAC MF9450, EPID L-2016-LRC-0001, OMB 3150-0231 | |
| Download: ML17285B196 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 27, 2017 OMB Control No. 3150-0231 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
CALVERT CLIFFS NUCLEAR POWER PLANT, UNIT 1; CLINTON POWER STATION, UNIT NO. 1; JAMES A FITZPATRICK NUCLEAR POWER PLANT; NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2; AND THREE MILE ISLAND NUCLEAR STATION, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 2016-01, "MONITORING OF NEUTRON-ABSORBING MATERIALS IN SPENT FUEL POOLS" (CAC NOS. MF9450, MF9448, MF9440, MF9429, MF9428, AND MF9414, EPID L-2016-LRC-0001)
Dear Mr. Hanson:
On April 7, 2016, the U.S. Nuclear Regulatory Commission (NRG) issued Generic Letter (GL) 2016-01, "Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16097A169).
GL 2016-01 requested power reactor licensees to provide information demonstrating that neutron-absorbing materials in the spent fuel pool, which are credited in the criticality safety analyses, are in compliance with the licensing basis, design bases, and regulatory requirements, and that measures are in place to maintain this compliance.
By letter dated November 3, 2016 (ADAMS Accession No. ML16308A470), Exelon Generation Company, LLC (Exelon, the licensee) submitted its response to GL 2016-01 for Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Clinton Power Station, Unit No. 1; Dresden Nuclear Power Station, Units 2 and 3; LaSalle County Station, Units 1 and 2: Limerick Generating Station, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2; Oyster Creek Nuclear Generating Station; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Power Station, Units 1 and 2: R. E.
Ginna Nuclear Power Plant; and Three Mile Island Nuclear Station, Unit 1. By letter dated April 27, 2017 (ADAMS Accession No. ML17117A554), the licensee provided supplemental information for Calvert Cliffs Nuclear Power Plant, Unit 1; Nine Mile Point Nuclear Station Unit No. 1; and Oyster Creek Nuclear Generating Station. This supplement was provided in response to an NRG letter dated March 9, 2017 (ADAMS Accession Nos. ML17041A369). By letter dated July 20, 2017 (ADAMS Accession No. ML172010359), the licensee provided supplemental information for Clinton Power Station, Unit No. 1.
By letter dated November 3, 2016 (ADAMS Accession No. ML16308A461 ), Entergy Nuclear Operations, Inc. submitted its response to GL 2016-01 for the James A. FitzPatrick Nuclear Power Plant. On March 1, 2017, the NRG issued an order (ADAMS Accession No. ML17041A196) approving transfer of the James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 from Entergy Nuclear FitzPatrick, LLC and Entergy Nuclear Operations, 1nc. to Exelon. The order was executed on March 31, 2017 (ADAMS Accession No. ML17090A188)
The NRC staff has determined that additional information is needed to complete the review of the response to GL 2016-01 for Calvert Cliffs Nuclear Power Plant, Unit 1; Clinton Power Station, Unit No. 1: James A. FitzPatrick Nuclear Power Plant; Nine Mile Point Nuclear Station, Units 1 and 2; and Three Mile Island Nuclear Station, Unit 1. A response to the enclosed request for additional information shall be provided within 60 days from the date of this letter.
Should you have any questions, please contact me at 301-415-1380 or by email at blake purnell{Wnr*c gov.
Docket Nos. 50-317, 50-461, 50-333, 50-220, 50-41 o, and 50-289 Blake Purnell, Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Enclosure:
Request for Additional Information cc w/encl: Distribution via Listserv
REQUEST FOR ADDITIONAL INFORMATION GENERIC LETTER 2016-01 "MONITORING OF NEUTRON-ABSORBING MATERIALS IN SPENT FUEL POOLS" EXELON GENERATION COMPANY LLC CALVERT CLIFFS NUCLEAR POWER PLANT UNIT 1 CLINTON POWER STATION UNIT NO. 1 JAMES A. FITZPATRICK NUCLEAR POWER PLANT NINE MILE POINT NUCLEAR STATION UNITS 1AND2 THREE MILE ISLAND NUCLEAR STATION UNIT 1 DOCKET NOS. 50-317 50-461 50-333 50-220 50-410 and 50-289 On April 7, 2016, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2016-01, "Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16097A169).
GL 2016-01 requested power reactor licensees to provide information demonstrating that neutron-absorbing materials in the spent fuel pool, which are credited in the criticality safety analyses, are in compliance with the licensing basis, design bases, and regulatory requirements, and that measures are in place to maintain this compliance. Appendix A to GL 2016-01 provided guidance applicable to certain licensee on the level of detail expected for the response to the request.
By letter dated November 3, 2016 (ADAMS Accession No. ML16308A470), Exelon Generation Company, LLC (Exelon, the licensee) submitted its response to GL 2016M01 for Braidwood Station, Units 1 and 2, Byron Station, Unit Nos. 1 and 2; Calvert Cliffs Nuclear Power Plant (CCNPP), Units 1 and 2; Clinton Power Station (CPS), Unit No. 1; Dresden Nuclear Power Station, Units 2 and 3; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2 (NMP1 and NMP2, respectively);
Oyster Creek Nuclear Generating Station; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Power Station, Units 1 and 2; R. E. Ginna Nuclear Power Plant; and Three Mile Island Nuclear Station (TMI), Unit 1. By letter dated April 27, 2017 (ADAMS Accession No. ML17117A554), the licensee provided supplemental information for CCNPP Unit 1, NMP1, and Oyster Creek Nuclear Generating Station. This supplement was provided in response to an NRG letter dated March 9, 2017 (ADAMS Accession Nos. ML17041A369). By letter dated July 20, 2017 (ADAMS Accession No. ML172010359), the licensee provided supplemental information for CPS.
Enclosure By letter dated November 3, 2016 (ADAMS Accession No. ML16308A461}, Entergy Nuclear Operations, lnc. (Entergy) submitted its response to GL 2016-01 for the James A. FitzPatrick Nuclear Power Plant (JAF). On March 1, 2017, the NRG issued an order (ADAMS Accession No. ML17041A196) approving transfer of the JAF Renewed Facility Operating License No. DPR-59 from Entergy Nuclear FitzPatrick, LLC and Entergy to Exelon. The order was executed on March 31, 2017 (ADAMS Accession No. ML17090A188).
The NRC staff has determined that the additional information below is needed to complete the review of the response to GL 2016-01 for CCNPP Unit 1, CPS, JAF, NMP1, NMP2, and TMI.
Calvert Cliffs Nuclear Power Plant. Unit 1 In GL 2016-01, the NRC staff requested (Area 2) "a description of the surveillance or monitoring program used to confirm that the credited neutron-absorbing material is performing its safety function, including the frequency, limitations, and accuracy of the methodologies used." For licensees that have a coupon monitoring program, the Appendix A, Section 2(b)(ii)(1), guidance states, in part, that licensees should "provide a description and technical basis for how the coupons are representative of the material in the racks."
For CCNPP Unit 1, the licensee's April 27, 2017, response to Appendix A, Section 1(e)(iii),
states that the acceptance criterion for weight change of the Carborundum material was not met during the 2013 coupon tests. The licensee stated that this weight loss was due to flow-induced erosion through an inspection hole in the coupon bracket cover, and that Carborundum in the spent fuel racks is not susceptible to this type of erosion.
CCNPP-RAl-1 The licensee stated that there is an inspection hole above the top of active fuel (TAF) in the spent fuel pool racks, but the flow-induced erosion will not impact the Carborundum below the TAF (i.e., the region credited in the spent fuel pool criticality analysis of record). Explain why it is not possible for flow-induced erosion or dissolution of the Carborundum material to occur below the TAF.
CCNPP-RAl-2 Explain how the Carborundum coupons are, and will continue to be, representative of the inservice material if the flow-induced erosion only affects the coupons and the data from the most eroded coupons is not considered.
CCNPP-RAl-3 In the response to Appendix A, Section 1(e)(iii), the licensee noted that bracket covers were installed to cover the holes on the coupon brackets in 2016. However, the inservice spent fuel racks still have an inspection hole above the TAF which could expose the inservice Carborundum to the spent fuel pool water. Given that the Carborundum coupons are no longer exposed to the complete spent fuel pool environment, describe how the coupons are representative of the inservice material.
CCNPP-RAl-4 The response to Appendix A, Section 1(e)(iii), states that the licensee plans to include measurement of the boron-1 O (108) areal density as part of the future coupon testing, and the associated procedural change is in progress. Given that the acceptance criterion for the coupon test was not met in 2013, confirm that:
- a.
the procedure change to incorporate measurement of 10s areal density has been incorporated into plant procedures; and
- b. all future coupon tests will include measurement of 108 areal density.
Clinton Power Station. Unit No. 1 Industry operating experience, as described in Information Notice (IN) 2009-26, "Degradation of Neutron-Absorbing Materials in the Spent Fuel Pool" (ADAMS Accession No. ML092440545) and IN 83-29, "Fuel Binding Caused by Fuel Rack Deformation" (ADAMS Accession No. ML14043A291), has demonstrated that certain manufacturing processes and plant conditions (e.g., dose, chemistry, length of time installed, and installation configuration) have resulted in material deformation as a result of blisters or bulging associated with Boral.
CPS-RAl-1 (Generic RAI)
The licensee's November 3, 2016, letter states that CPS does not have a site-specific monitoring program. Instead, the licensee is relying on general industry operating experience as a surrogate for the condition of the Boral installed in the CPS spent fuel pool.
- a. Describe how industry operating experience bounds the condition of the Boral at CPS, thereby providing assurance that any degradation or deformation that may affect the Boral at CPS is identified.
- b.
Discuss the criticality impact due to relevant material deformation identified in general industry operating experience, and how it can be accommodated by the nuclear criticality safety analysis of record for CPS without exceeding subcriticality requirements.
James A. Fitzpatrick Nuclear Power Plant Entergy's November 3, 2016, letter indicates that the JAF monitoring program has identified material deformation associated with blisters in Boral similar to the industry operating experience described in IN 2009-26.
JAF-RAl-1 (Generic RAI)
Discuss the criticality impact due to the material deformation identified at JAF, and how it can be accommodated by the nuclear criticality safety analysis of record without exceeding subcriticality requirements.
Nine Mile Point Nuclear Station Unit No. 1 For NMP1, license renewal commitment No. 16 states 1*
The Boraflex Monitoring Program will be enhanced to (1) Require periodic neutron attenuation testing and measurement of boron areal density to confirm the correlation of the conditions of test coupons to those of Boraflex racks that remain in use during the period of extended operation: and (2) Establish monitoring and trending instructions for in-situ test results, silica levels, and coupon results.
In its April 27, 2017, response to Appendix A, Section 2(a)(1), the licensee stated that the frequency for testing of Boraflex in the NMP1 spent fuel pool, using a Boron-10 Areal Density Gauge for Evaluation Racks (BADGER), was initially set at once prior to the period of extended operation and then once every 8 years afterwards. The licensee performed the first BADGER testing in 2008. However, the licensee stated that NMP1 will not conduct BADGER testing at the first 8-year interval due to a combination of Boraflex coupon results, RACKLIFE computer code projections, and a planned new SFP nuclear criticality safety analysis of record to remove credit for Boraflex.
NMP1-RAl-1 Explain how NMP1 complies with license renewal commitment No. 16, including monitoring and trending of in-situ test results, if BADGER testing will not be conducted periodically during the period of extended operation.
Nine Mile Point Nuclear Station, Unit 2 In its November 3, 2016, response to Appendix A, Section 2(a)(lli), the licensee stated that:
"The [NMP2] BADGER acceptance criteria is that no measured Boral panel average areal density be below the minimum certified areal density of the material when the accuracy of the measurement is taken into account."
NMP2-RAl-1 Justify the use of the panel average 10B areal density as the acceptance criterion, instead of the lowest measured 10B areal density at a given point on the panel.
NMP2-RAl-2 Explain how measurement uncertainty is accounted for in the acceptance criteria for BADGER testing.
Three Mile Island Nuclear Station, Unit 1 In its November 3, 2016, response to Appendix A, Section 2(a)(i), the licensee stated that the current frequency for Metamic coupon surveillances is one coupon every 2 years. The 1 NMP1 license renewal commitments are listed in Appendix A to NUREG-1900, Volume 2. "Safety Evaluation Report Related to the License Renewal of Nine Mile Point Nuclear Station, Units 1 and 2,"
published September 2006 (ADAMS Accession No. ML062890236).
response also states that this frequency may decrease as experience is gained with the material TMl-RAl-1 Provide the basis for determining the Metamic coupon surveillance frequency. Provide the minimum Metamic coupon surveillance frequency allowed by the program.
- ML17285B196 "via email OFFICE NRR/DORL/LSPB/PM NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NAME swa11*
BPurnell SRohrer DATE 10/12/17 10/26/17 10/16/17 OFFICE NRR/DLR/RCCB*
NRR/DPR/PGCB/BC(A)'
NRR/DSS/SNPB/BC*
NAME SBloom AGarmoe Rlukes DATE 09/25/17 09/22/17 09/21/17 OFFICE NRR/DORL/LPL3/BC NRRIDORL/LPL3/PM NAME DWrona BPurnell DATE 10/27/17 10/27/17