ML18241A082
| ML18241A082 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 12/06/2018 |
| From: | Victor Cusumano NRC/NRR/DSS/STSB |
| To: | Technical Specifications Task Force |
| Honcharik M, NRR/DSS, 301-415-1774 | |
| Shared Package | |
| ML18241A087 | List: |
| References | |
| EPID L-2017-PMP-0025 | |
| Download: ML18241A082 (7) | |
Text
Enclosure 2 General Directions: This Model safety evaluation (SE) provides the format and content to be 1
used when preparing the plant-specific SE of a license amendment request (LAR) to adopt 2
TSTF-557. The bolded bracketed information shows text that should be filled in for the specific 3
amendment; individual licensees would furnish site-specific nomenclature or values for these 4
bracketed items. The italicized wording provides guidance on what should be included in each 5
section and should not be included in the SE.
6 7
DRAFT MODEL SAFETY EVALUATION 8
9 BY THE OFFICE OF NUCLEAR REACTOR REGULATION 10 11 TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER 12 13 TSTF-557, REVISION 1, 14 15 SPENT FUEL STORAGE RACK NEUTRON ABSORBER MONITORING PROGRAM 16 17 USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS 18 19 (EPID L-2017-PMP-0025) 20 21 22
1.0 INTRODUCTION
23 24 By application dated [enter date], (Agencywide Documents Access and Management System 25 (ADAMS) Accession No. [MLXXXXXXXXX]), [as supplemented by letters dated [enter 26 date(s))), [name of licensee] (the licensee) submitted a license amendment request (LAR) for 27
[name of facility (abbreviated name), applicable units].
28 29 The amendment would revise Technical Specification (TS) Section 5.5, Programs and 30 Manuals. The proposed change would add a new program titled, Spent Fuel Storage Rack 31 Neutron Absorber Monitoring Program. The program ensures the boron-10 areal density of the 32 neutron absorber material assumed in the spent fuel pool (SFP) storage rack nuclear criticality 33 analyses remains conservative with respect to the actual plant conditions. The proposed 34 changes are based on Technical Specifications Task Force (TSTF) Traveler TSTF-557, 35 Revision 1, Spent Fuel Storage Rack Neutron Absorber Monitoring Program, dated 36 December 19, 2017 (ADAMS Accession No. ML17353A608). The U.S. Nuclear Regulatory 37 Commission (NRC or the Commission) issued a final safety evaluation (SE) approving 38 TSTF-557, Revision 1, on [enter date] (ADAMS Accession No. MLXXXXXXXXX).
39 40
[The licensee has proposed variations from the TS changes described in TSTF-557. The 41 variations are described in Section 2.2.1 of this SE and evaluated in Section 3.3.] [The 42 licensee is not proposing any variations from the TS changes described in TSTF-557 or 43 the applicable parts of the NRC staffs SE of TSTF-557.]
44 45
[The supplemental letters dated [enter date(s)], provided additional information that 46 clarified the application, did not expand the scope of the application as originally 47 noticed, and did not change the NRC staffs original proposed no significant hazards 48 consideration determination as published in the Federal Register on [enter date] (cite FR 49 reference).]
50 51
2.0 REGULATORY EVALUATION
1 2
2.1 DESCRIPTION
OF SPENT FUEL POOL STORAGE RACKS 3
4 The credited neutron absorbing material (NAM) installed in SFP storage racks ensures that the 5
effective multiplication factor (k-effective, keff) does not exceed the values and assumptions 6
used in the criticality analysis of record (AOR) and other licensing basis documents. The AOR 7
is the basis, in part, for demonstrating compliance with plant TS and with applicable NRC 8
regulations. Degradation or deformation of the credited NAM may reduce safety margin and 9
potentially challenge the subcriticality requirement. The NAM utilized in SFP racks exposed to 10 treated water or treated borated water may be susceptible to reduction of neutron absorbing 11 capacity, changes in dimension that increase keff, and loss of material. A monitoring program is 12 implemented to ensure that degradation of the NAM used in SFPs, which could compromise the 13 ability of the NAM to perform its safety function as assumed in the AOR, will be detected.
14 15
2.2 PROPOSED CHANGE
S TO THE TECHNICAL SPECIFICATIONS 16 17 A new program would be added to TS Section [5.5, Program and Manuals.] The new 18 program would appear as:
19 20 5.5.[XX]
Spent Fuel Storage Rack Neutron Absorber Monitoring Program 21 22 This Program provides controls for monitoring the condition of the 23 neutron absorber used in the spent fuel pool storage racks to 24 verify the Boron-10 areal density is consistent with the 25 assumptions in the spent fuel pool criticality analysis. The 26 program shall be in accordance with NEI 16-03-A, Guidance for 27 Monitoring of Fixed Neutron Absorbers in Spent Fuel Pools, 28 Revision 0, May 2017[, with the following exceptions:
29 30
- 1. ]
31 32
[2.2.1 Variations from TSTF-557 and exceptions to NEI 16-03-A]
33 34
{NOTE: Technical reviewers and/or project manager are to assess the adequacy of any 35 variations from the approved traveler and document their acceptability. Choose the applicable 36 paragraphs based on information provided in the LAR.}
37 38
[The licensee is proposing the following exceptions to NEI 16-03-A and/or variations from 39 the TS changes described in TSTF-557, or the applicable parts of the NRC staffs SE of 40 TSTF-557. [Describe the variations and/or exceptions.]
41 42
[The [PLANT] TS utilize different [numbering][and][titles] than the Standard Technical 43 Specifications on which TSTF-557 was based. Specifically, [describe differences 44 between the plant-specific TS numbering and/or titles and the TSTF-557 numbering 45 and/or titles.]
46 47
[The [PLANT] design is different than the model plant assumed in the Standard Technical 48 Specifications. [Describe differences.))
49 1
2.3 APPLICABLE REGULATORY REQUIREMENTS AND GUIDANCE 2
3 Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(a)(1) requires each 4
applicant for a license authorizing operation of a utilization facility to include in the application 5
proposed TS.
6 7
The regulation at 10 CFR 50.36(b) requires:
8 9
Each license authorizing operation of a utilization facility will 10 include technical specifications. The technical specifications will 11 be derived from the analyses and evaluation included in the safety 12 analysis report, and amendments thereto, submitted pursuant to 13
[10 CFR] 50.34 [Contents of applications; technical information].
14 The Commission may include such additional technical 15 specifications as the Commission finds appropriate.
16 17 The regulation at 10 CFR 50.36(c)(5) requires TS to include administrative controls, which are 18 the provisions relating to organization and management, procedures, recordkeeping, review and 19 audit, and reporting necessary to assure operation of the facility in a safe manner.
20 21 The regulation in paragraph (b)(4) of 10 CFR 50.68, Criticality accident requirements, states 22 that if the licensee does not credit soluble boron in the SFP criticality AOR, the keff of the SFP 23 storage racks must not exceed 0.95 at a 95 percent probability, 95 percent confidence level. If 24 the licensee does take credit for soluble boron, the keff of the SFP storage racks must not 25 exceed 0.95 at a 95 percent probability, 95 percent confidence level, if the racks are flooded 26 with borated water, and if flooded with unborated water, the keff must remain below 1.0 at a 27 95 percent probability, 95 percent confidence level.
28 29 The NRC staffs guidance for the review of TS is in Chapter 16.0, Technical Specifications, of 30 NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for 31 Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP), March 2010 (ADAMS 32 Accession No. ML100351425). As described therein, as part of the regulatory standardization 33 effort, the NRC staff has prepared Standard Technical Specifications (STS) for each of the LWR 34 nuclear designs. Accordingly, the NRC staffs review includes consideration of whether the 35 proposed changes are consistent with the applicable reference STS (i.e., the current STS), as 36 modified by NRC-approved travelers. In addition, the guidance states that comparing the 37 change to previous STS can help clarify the TS intent.
38 39 Section 9.1.1, Revision 3, of the SRP, Criticality Safety of Fresh and Spent Fuel Storage and 40 Handling, March 2007 (ADAMS Accession No. ML070570006), provides guidance regarding 41 the acceptance criteria and review procedures to ensure that the proposed changes satisfy the 42 requirements in 10 CFR 50.68.
43 44 Section 9.1.2, Revision 4, of the SRP, New and Spent Fuel Storage (ADAMS Accession 45 No. ML070550057), provides guidance regarding the acceptance criteria and review procedures 46 to ensure that the proposed changes satisfy the requirements in 10 CFR 50.68.
47 48
{NOTE: Choose applicable STS}
49
[U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Babcock and 50 Wilcox Plants, NUREG-1430, Volume 1, Specifications, and Volume 2, Bases, 51 Revision 4.0, April 2012 (ADAMS Accession Nos. ML12100A177 and ML12100A178, 1
respectively).
2 3
U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Westinghouse 4
Plants, NUREG-1431, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, 5
April 2012 (ADAMS Accession Nos. ML12100A222 and ML12100A228, respectively).
6 7
U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Combustion 8
Engineering Plants, NUREG-1432, Volume 1, Specifications, and Volume 2, Bases, 9
Revision 4.0, April 2012 (ADAMS Accession Nos. ML12102A165 and ML12102A169, 10 respectively).
11 12 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General 13 Electric BWR/4 Plants, NUREG-1433, Volume 1, Specifications, and Volume 2, 14 Bases, Revision 4.0, dated April 2012 (ADAMS Accession Nos. ML12104A192 and 15 ML12104A193, respectively).
16 17 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General 18 Electric BWR/6 Plants, NUREG-1434, Volume 1, Specifications, and Volume 2, 19 Bases, Revision 4.0, April 2012 (ADAMS Accession Nos. ML12104A195 and 20 ML12104A196, respectively).
21 22 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Westinghouse 23 Advanced Passive 1000 (AP1000) Plants, NUREG-2194, Revision 0, April 2016, 24 Volume 1, Specifications, and Volume 2, Bases (ADAMS Accession 25 Nos. ML16110A277 and ML16110A369, respectively).]
26 27 NUREG-1801, Revision 2, Generic Aging Lessons Learned (GALL) Report, December 2010 28 (ADAMS Accession No. ML103490041), provides guidance on what constitutes an acceptable 29 monitoring program for NAM credited for criticality control in the SFP.
30 31 The TS Section [5.5] program imposes a requirement to have a licensee-controlled program 32 that is in accordance with Nuclear Energy Institute (NEI) topical report NEI 16-03-A, Guidance 33 for Monitoring of Fixed Neutron Absorbers in Spent Fuel Pools, Revision 0, dated May 26, 2017 34 (ADAMS Accession No. ML17263A133). The NRC staff approved NEI 16-03 in an SE dated 35 March 3, 2017 (ADAMS Accession No. ML16354A486). The NEI 16-03-A topical report and the 36 NRC staffs SE for NEI 16-03 provide the technical justification for the proposed program.
37 38
[PLANT] TS Section [4, Design Features, Section 4.3, Fuel Storage,] provides limits on 39 the SFP storage racks, including limits on keff in various conditions. [LICENSEE] has credited 40 NAM in the SFP storage racks at [PLANT] to meet these requirements. There are currently 41
[no] requirements in the TS that require monitoring the condition of the NAM in the SFP. [The 42 TS requirements for monitoring the condition of the NAM in the SFP are contained in 43 TS XX.]
44 45
3.0 TECHNICAL EVALUATION
46 47 The licensee stated in Section 2.1 of the LAR that it had reviewed the NRC staffs SE of 48 TSTF-557, Revision 1, as well as the information provided in TSTF-557, Revision 1, and 49 concluded that the justifications presented in TSTF-557, Revision 1, and the SE prepared by the 50 NRC staff are applicable to [PLANT] and justify the proposed changes.
51 1
The NRC staff reviewed the proposed changes to the TS. The NRC staff reviewed the changes 2
to ensure the licensee properly accounted for any limitations or conditions placed on adoption of 3
TSTF-557. In addition, the NRC staff reviewed the proposed TS changes to ensure the TS, as 4
modified by adoption of TSTF-557, would continue to comply with the requirements of 5
6 7
3.1 NEW PROGRAM FOR MONITORING NEUTRON ABSORBER 8
9 The purpose of the program is to ensure the boron-10 areal density of the neutron absorber 10 material assumed in the SFP storage rack nuclear criticality analyses remains conservative with 11 respect to the actual plant conditions.
12 13 The TS Section [5.5] program imposes a requirement to have a licensee-controlled program 14 that is in accordance with NEI 16-03-A, Guidance for Monitoring of Fixed Neutron Absorbers in 15 Spent Fuel Pools, Revision 0, May 2017. In the SE for NEI 16-03, dated March 3, 2017, the 16 NRC approved and accepted the document for referencing in licensing applications for nuclear 17 power plants. The NEI 16-03-A topical report and the NRCs SE for NEI 16-03 provide the 18 technical justification for the proposed program.
19 20 The purpose of a NAM monitoring program is to verify that the NAM installed in SFPs continues 21 to perform its safety function (i.e., criticality control) as assumed in the AOR. The guidance 22 provided in NEI 16-03 for a NAM monitoring program relies on periodic inspection, testing, 23 monitoring, and analysis of the NAM to ensure that the required subcriticality margin is 24 maintained in accordance with 10 CFR 50.68 requirements. To accomplish this purpose, the 25 guidance document states that a monitoring program must be capable of identifying 26 unanticipated changes in the absorber material and determining whether anticipated changes 27 can be verified. The guidance recommends a combination of coupon testing, in situ 28 measurement, and SFP water chemistry monitoring as a means to monitor potential changes in 29 characteristics of the NAM.
30 31 The NRC staff reviewed the proposed guidance for what constitutes an acceptable monitoring 32 program and its ability to ensure that potential degradation of SFP NAM will be detected, 33 monitored, and mitigated. In the NRCs SE for NEI 16-03, the staff determined that an 34 appropriate combination of the three methods listed above (coupon testing, in situ 35 measurement, and SFP water chemistry monitoring) as described in NEI 16-03-A, can comprise 36 an effective NAM monitoring program. Section 3.4 of the NRCs SE of NEI 16-03 states that in 37 order for a NAM program to be acceptable, a licensee must perform neutron attenuation testing 38 to verify the boron-10 areal density. Further, in Section 4.0 of the NRCs SE for NEI 16-03, the 39 NRC staff concluded that a NAM monitoring program implementing the guidance in NEI 16-03 40 provides reasonable assurance that such program will be able to detect degradation of neutron 41 absorbing material, and provides assurance that the ability of the NAM to provide the criticality 42 control relied upon in the AOR, is maintained.
43 44 Based on its review of the proposed TS changes and previous approval of NEI 16-03, the NRC 45 staff has determined that the licensees NAM monitoring program meets the provisions in 46 NEI 16-03-A. Therefore, the NRC staff finds that the ability of the NAM to perform its safety 47 function, as assumed in the AOR, is maintained, thus demonstrating compliance with the 48 subcriticality requirements of 10 CFR 50.68.
49 50 3.2 CONTINUED COMPLIANCE WITH THE REQUIREMENTS OF 10 CFR 50.36.
1 2
[PLANT] TS Section [5.5], as modified by adoption of TSTF-557, will continue to contain 3
provisions relating to procedures, recordkeeping, review and audit, and reporting necessary to 4
assure operation of the facility in a safe manner. The NRC staff determined that the TS, as 5
modified, would continue to comply with the requirements of 10 CFR 50.36. Therefore, the staff 6
determined that the proposed change is acceptable.
7 8
{NOTE: Technical reviewers and/or project manager are to assess the adequacy of any 9
variations from the approved traveler and document their acceptability. Choose the applicable 10 paragraphs based on information provided in the LAR.}
11 12
[3.3 VARIATIONS FROM TSTF-557 AND EXCEPTIONS TO NEI 16-03-A 13 14 The licensee described variations from TSTF-557 and exceptions to NEI 16-03-A in 15 Section 2.2 of the LAR. The licensee provided justification for the proposed variations 16 and exceptions. Describe why TSTF-557 is still applicable.
17 18 The NRC staff reviewed the justifications and concluded the exceptions and variations 19 from TSTF-557 are [not] acceptable because.
20 21 The NRC staff reviewed the justifications for the proposed exceptions to NEI 16-03-A and 22 concluded the exceptions are [not] acceptable because 23 24 The [PLANT] TS utilize different [numbering][and][titles] than the STS on which TSTF-557 25 was based. The NRC staff agrees these differences are editorial and do not affect the 26 applicability of TSTF-557 to the proposed LAR.
27 28 The [PLANT] design is different than the model plant assumed in the STSs, but the 29 TSTF-557 justification and the NRC staffs SE are still applicable. The NRC staff reviewed 30 the design differences and concluded differences are [not] acceptable because.]
31 32 3.[4]
TECHNICAL EVALUATION
SUMMARY
33 34 The regulations at 10 CFR 50.36 require that TS will include items in specified categories, 35 including administrative controls. Based on its review of the proposed TS changes and previous 36 approval of NEI 16-03, the NRC staff has determined that the licensees NAM monitoring 37 program meets the applicable provisions in NEI 16-03-A. Therefore, the NRC staff finds that the 38 ability of the NAM to perform its safety function, as assumed in the AOR, is maintained, thus 39 demonstrating compliance with the subcriticality requirements of 10 CFR 50.68. The NRC staff 40 finds that the proposed new monitoring program, as adopted by [LICENSEE], allows [PLANT]
41 TS to continue to meet the requirements of 10 CFR 50.36(c)(5). Therefore, the staff determined 42 that the proposed change is acceptable.
43 44
4.0 STATE CONSULTATION
45 46
{This section is to be prepared by the plant project manager.}
47 48 In accordance with the Commissions regulations, the [Name of State] State official was notified 49 of the proposed issuance of the amendment(s) on [date]. The State official had [no]
50 comments. [If comments were provided, they should be addressed here.]
51 1
5.0 ENVIRONMENTAL CONSIDERATION
2 3
{This section is to be prepared by the plant project manager in accordance with current 4
procedures.}
5 6
6.0 CONCLUSION
7 8
{This section is to be prepared by the plant project manager.}
9 10 The Commission has concluded, based on the considerations discussed above, that: (1) there 11 is reasonable assurance that the health and safety of the public will not be endangered by 12 operation in the proposed manner, (2) there is reasonable assurance that such activities will be 13 conducted in compliance with the Commissions regulations, and (3) the issuance of the 14 amendment(s) will not be inimical to the common defense and security or to the health and 15 safety of the public.
16 17
7.0 REFERENCES
18 19
{Optional section to be prepared by the PM and primary reviewers. If a document is publicly 20 available, the ADAMS Accession No. should be listed.}
21 22
{NOTE: These are the principal contributors for the model SE of the traveler. Replace these 23 names with those who prepared the plant-specific SE.}
24 25 Principal Contributors: M. Hamm, NRR/DSS 26 M. Yoder, NRR/DLMR 27 28 Date:
29