ML23255A062

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Summary of August 7, 2023, Presubmittal Meeting with Vistra Operations Company LLC to Discuss the Proposed LAR to Relocate Refueling Operations TS 3.9.3, Nuclear Instrumentation, to the Technical Requirements Manual
ML23255A062
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 09/18/2023
From: Dennis Galvin
Plant Licensing Branch IV
To:
Vistra Operations Company
Galvin D
Shared Package
ML23255A075 List:
References
EPID L-2023-LRM-0052
Download: ML23255A062 (4)


Text

September 18, 2023 LICENSEE: Vistra Operations Company LLC FACILITY: Comanche Peak Nuclear Power Plant, Units Nos. 1 and 2

SUBJECT:

SUMMARY

OF AUGUST 7, 2023, PRESUBMITTAL MEETING WITH VISTRA OPERATIONS COMPANY LLC TO DISCUSS PROPOSED LICENSE AMENDMENT REQUEST TO RELOCATE REFUELING OPERATIONS TECHNICAL SPECIFICATION 3.9.3, NUCLEAR INSTRUMENTATION, TO THE TECHNICAL REQUIREMENTS MANUAL (EPID L-2023-LRM-0052)

On August 7, 2023, an Observation public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of Vistra Operations Company LLC (the licensee) via webinar. The purpose of the meeting was to discuss a proposed license amendment request (LAR) to relocate refueling operations Technical Specification (TS) 3.9.3, Nuclear Instrumentation, to the Technical Requirements Manual (TRM) at the Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2 (Comanche Peak Units 1 and 2). The meeting notice and agenda, dated July 25, 2023, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML23207A162. A list of attendees is enclosed.

The licensee presented informational slides at the meeting, which can be found in ADAMS at Accession No. ML23215A192. During the meeting, the licensee discussed the proposed TS change and its proposed justification for the TS change. The licensee presented its basis for why TS 3.9.3 doesnt meet the four criteria in Title 10 of the Code of Federal Regulations (10 CFR) paragraph 50.36(c)(2)(ii) and thus may be relocated to the TRM.

The NRC staff had observations on the justifications presented by the licensee for the proposed LAR and their conflict with the bases in NUREG-1431, Standard Technical Specifications, Westinghouse Plants, Revision 5.0, Volume 2, Bases (ML21259A159) (STS Bases). The NRC staff referred to the Applicable Safety Analyses section of the STS 3.9.3 Bases, which states in part that, Two OPERABLE source range neutron flux monitors are required to provide a signal to alert the operator to unexpected changes in core reactivity such as with a boron dilution accident or an improperly loaded fuel assembly. The NRC staff acknowledged that the STS 3.9.3 Bases contains a reviewers note that states, The need for a safety analysis for an uncontrolled boron dilution accident is eliminated by isolating all unborated water sources as required by LCO [Limiting Condition for Operation] 3.9.2, Unborated Water Source Isolation Valves, which applies to Comanche Peak. The NRC staff noted that the STS 3.9.3 Bases state that The source range neutron flux monitors satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii) and has stated so since NUREG-1431 was issued in September 1992. The NRC staff stated that it considers an improperly loaded fuel assembly credible and that the source range neutron flux monitors would detect unexpected changes in core reactivity such as with a boron dilution accident or an improperly loaded fuel assembly, which is one of their stated functions. The NRC

staff further noted that There are no other direct means available to check core reactivity levels, as stated in the Applicability section of the STS 3.9.3 Bases. The NRC staff also noted that the presentation statement that the Comanche Peak plant-specific probabilistic risk assessment (PRA) does not address Mode 6 (refueling) operations and would not be a basis for concluding that the PRA has not shown the source range neutron flux monitors to be significant, which is related to Criterion 4 of 10 CFR 50.36(c)(2)(ii).

No members of the public called into the meeting. No public meeting feedback forms were received. No regulatory decisions were made at the meeting.

Please direct any inquiries to me at 301-415-6256 or by e-mail to Dennis.Galvin@nrc.gov.

/RA/

Dennis J. Galvin, Project Manager Plant Licensing Branch IV Division of Operator Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosure:

List of Attendees cc: Listserv

LIST OF ATTENDEES AUGUST 7, 2023, PRESUBMITTAL WEBINAR REGARDING PROPOSED LICENSE AMENDMENT REQUEST TO RELOCATE REFUELING OPERATIONS TECHNICAL SPECIFICATION 3.9.3, NUCLEAR INSTRUMENTATION, TO THE TECHNICAL REQUIREMENTS MANUAL VISTRA OPERATIONS COMPANY LLC COMANCHE PEAK NUCLEAR POWER PLANT, UNITS NO. 1 AND 2 U.S. Nuclear Regulatory Commission Clinton Ashley Santosh Bhatt Dennis Galvin Michele Kichline Hang Vu Kent Wood Vistra Operations Company LLC Kris Brigman Jack Hicks Nic Boehmisch Westinghouse/Pressurized Water Reactor Owners Group James Andrachek Andrew Howe Chad Holderbaum Enclosure

ML23255A075 (Package)

ML23207A162 (Meeting Notice)

ML23215A192 (Public Meeting Slides)

ML23255A062 (Meeting Summary)

OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DEX/ECIB/BC(A)

NAME DGalvin PBlechman RStattel DATE 9/12/2023 9/12/2023 9/15/2023 OFFICE NRR/DRA/APOB/BC NRR/DSS/SFNB/BC NRR/DSS/SNSB/BC NAME AZoulis SKrepel PSahd DATE 9/11/2023 9/14/2023 9/12/2023 OFFICE NRR/DSS/STSB/BC (A) NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME MJardaneh JDixon-Herrity DGalvin DATE 9/12/2023 9/18/2023 9/18/2023