TSTF-18-13, TSTF Comments on Draft Safety Evaluation for Traveler TSTF-557, Revision 1, Spent Fuel Storage Rack Neutron Absorber Monitoring Program.
| ML18354B025 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force, 99902042 |
| Issue date: | 12/20/2018 |
| From: | Gullott D, Joyce R, Miksa J, Sparkman W, Vaughan J Technical Specifications Task Force |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TSTF-18-13, TSTF-557, Rev 1 | |
| Download: ML18354B025 (11) | |
Text
TECHNICAL SPECIFICATIONS TASK FORCE TSTF A JOINT OWNERS GROUP ACTIVITY December 20, 2018 TSTF-18-13 PROJ0753 Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
TSTF Comments on Draft Safety Evaluation for Traveler TSTF-557, Revision 1, "Spent Fuel Storage Rack Neutron Absorber Monitoring Program"
REFERENCE:
Letter Victor Cusumano (NRC) to the TSTF, "Draft Safety Evaluations of Technical Specifications Task Force Traveler TSTF-557, Revision 1, "Spent Fuel Storage Rack Neutron Absorber Monitoring Program," dated December 6, 2018 (ADAMS Accession No. ML18241A087).
On December 19, 2017, the TSTF submitted traveler TSTF-557, Revision 1, "Spent Fuel Storage Rack Neutron Absorber Monitoring Program," to the Nuclear Regulatory Commission (NRC) for review (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17353A608). In the referenced letter, the NRC provided the draft Safety Evaluations for TSTF-557 for comment.
Attachment 1 contains a summary table providing the TSTF's comments on the draft Safety Evaluations. Attachment 2 contains a mark-up reflecting the TSTF's comments.
Should you have any questions, please do not hesitate to contact us.
James P. Miksa (PWROG/CE) Ryan M. Joyce (BWROG)
David M. Gullott (PWROG/W) Jordan L. Vaughan (PWROG/B&W)
Wesley Sparkman (APOG) 11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Administration by EXCEL Services Corporation
TSTF-18-13 December 20, 2018 TSTF Comments on the TSTF-557 Draft Safety Evaluations TSTF Markup of Draft Model Safety Evaluation cc: Michelle Honcharik, Technical Specifications Branch, NRC Victor Cusumano, Technical Specifications Branch, NRC
Attachment 1 TSTF Comments on the TSTF-557 Draft Safety Evaluations The TSTF has no comments on the TSTF-557 Traveler Draft Safety Evaluation.
TSTF Comments on the TSTF-557 Draft Model Safety Evaluation Page(s) Line(s)1 Comment 3 1-6 The model application in TSTF-557 contains an optional variation for 6 38-45 plants that have existing requirements on neutron absorber material monitoring, and that request to delete those requirements and replace them with the proposed program. That optional variation should be reflected in the model Safety Evaluation with the other optional variations.
1 Line numbers correspond to the attached proposed revision, not to the documents provided by the NRC.
Page 3
Attachment 2 TSTF Markup of Draft Model Safety Evaluation
1 General Directions: This Model safety evaluation (SE) provides the format and content to be 2 used when preparing the plant-specific SE of a license amendment request (LAR) to adopt 3 TSTF-557. The bolded bracketed information shows text that should be filled in for the specific 4 amendment; individual licensees would furnish site-specific nomenclature or values for these 5 bracketed items. The italicized wording provides guidance on what should be included in each 6 section and should not be included in the SE.
7 8 DRAFT MODEL SAFETY EVALUATION 9
10 BY THE OFFICE OF NUCLEAR REACTOR REGULATION 11 12 TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER 13 14 TSTF-557, REVISION 1, 15 16 SPENT FUEL STORAGE RACK NEUTRON ABSORBER MONITORING PROGRAM 17 18 USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS 19 20 (EPID L-2017-PMP-0025) 21 22 23
1.0 INTRODUCTION
24 25 By application dated [enter date], (Agencywide Documents Access and Management System 26 (ADAMS) Accession No. [MLXXXXXXXXX]), [as supplemented by letters dated [enter 27 date(s))), [name of licensee] (the licensee) submitted a license amendment request (LAR) for 28 [name of facility (abbreviated name), applicable units].
29 30 The amendment would revise Technical Specification (TS) Section 5.5, Programs and 31 Manuals. The proposed change would add a new program titled, Spent Fuel Storage Rack 32 Neutron Absorber Monitoring Program. The program ensures the boron-10 areal density of the 33 neutron absorber material assumed in the spent fuel pool (SFP) storage rack nuclear criticality 34 analyses remains conservative with respect to the actual plant conditions. The proposed 35 changes are based on Technical Specifications Task Force (TSTF) Traveler TSTF-557, 36 Revision 1, Spent Fuel Storage Rack Neutron Absorber Monitoring Program, dated 37 December 19, 2017 (ADAMS Accession No. ML17353A608). The U.S. Nuclear Regulatory 38 Commission (NRC or the Commission) issued a final safety evaluation (SE) approving 39 TSTF-557, Revision 1, on [enter date] (ADAMS Accession No. MLXXXXXXXXX).
40 41 [The licensee has proposed variations from the TS changes described in TSTF-557. The 42 variations are described in Section 2.2.1 of this SE and evaluated in Section 3.3.] [The 43 licensee is not proposing any variations from the TS changes described in TSTF-557 or 44 the applicable parts of the NRC staffs SE of TSTF-557.]
45 46 [The supplemental letters dated [enter date(s)], provided additional information that 47 clarified the application, did not expand the scope of the application as originally 48 noticed, and did not change the NRC staffs original proposed no significant hazards 49 consideration determination as published in the Federal Register on [enter date] (cite FR 50 reference).]
51 Enclosure 2
1
2.0 REGULATORY EVALUATION
2 3
2.1 DESCRIPTION
OF SPENT FUEL POOL STORAGE RACKS 4
5 The credited neutron absorbing material (NAM) installed in SFP storage racks ensures that the 6 effective multiplication factor (k-effective, keff) does not exceed the values and assumptions 7 used in the criticality analysis of record (AOR) and other licensing basis documents. The AOR 8 is the basis, in part, for demonstrating compliance with plant TS and with applicable NRC 9 regulations. Degradation or deformation of the credited NAM may reduce safety margin and 10 potentially challenge the subcriticality requirement. The NAM utilized in SFP racks exposed to 11 treated water or treated borated water may be susceptible to reduction of neutron absorbing 12 capacity, changes in dimension that increase keff, and loss of material. A monitoring program is 13 implemented to ensure that degradation of the NAM used in SFPs, which could compromise the 14 ability of the NAM to perform its safety function as assumed in the AOR, will be detected.
15 16
2.2 PROPOSED CHANGE
S TO THE TECHNICAL SPECIFICATIONS 17 18 A new program would be added to TS Section [5.5, Program and Manuals.] The new 19 program would appear as:
20 21 5.5.[XX] Spent Fuel Storage Rack Neutron Absorber Monitoring Program 22 23 This Program provides controls for monitoring the condition of the 24 neutron absorber used in the spent fuel pool storage racks to 25 verify the Boron-10 areal density is consistent with the 26 assumptions in the spent fuel pool criticality analysis. The 27 program shall be in accordance with NEI 16-03-A, Guidance for 28 Monitoring of Fixed Neutron Absorbers in Spent Fuel Pools, 29 Revision 0, May 2017[, with the following exceptions:
30 31 1. ]
32 33 [2.2.1 Variations from TSTF-557 and exceptions to NEI 16-03-A]
34 35 {NOTE: Technical reviewers and/or project manager are to assess the adequacy of any 36 variations from the approved traveler and document their acceptability. Choose the applicable 37 paragraphs based on information provided in the LAR.}
38 39 [The licensee is proposing the following exceptions to NEI 16-03-A and/or variations from 40 the TS changes described in TSTF-557, or the applicable parts of the NRC staffs SE of 41 TSTF-557. [Describe the variations and/or exceptions.]
42 43 [The [PLANT] TS utilize different [numbering][and][titles] than the Standard Technical 44 Specifications on which TSTF-557 was based. Specifically, [describe differences 45 between the plant-specific TS numbering and/or titles and the TSTF-557 numbering 46 and/or titles.]
47 48 [The [PLANT] design is different than the model plant assumed in the Standard Technical 49 Specifications. [Describe differences.))
1 2 [The [PLANT] [TS / Operating License] contain Spent Fuel Pool storage rack neutron 3 absorber material monitoring requirements approved by the NRC in [Reference].
4 [Describe, at a high level, the existing requirements and location.] [LICENSEE] proposes 5 to replace the existing requirements with the TS Administrative Controls program in 6 TSTF-557.]
7 8 2.3 APPLICABLE REGULATORY REQUIREMENTS AND GUIDANCE 9
10 Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(a)(1) requires each 11 applicant for a license authorizing operation of a utilization facility to include in the application 12 proposed TS.
13 14 The regulation at 10 CFR 50.36(b) requires:
15 16 Each license authorizing operation of a utilization facility will 17 include technical specifications. The technical specifications will 18 be derived from the analyses and evaluation included in the safety 19 analysis report, and amendments thereto, submitted pursuant to 20 [10 CFR] 50.34 [Contents of applications; technical information].
21 The Commission may include such additional technical 22 specifications as the Commission finds appropriate.
23 24 The regulation at 10 CFR 50.36(c)(5) requires TS to include administrative controls, which are 25 the provisions relating to organization and management, procedures, recordkeeping, review and 26 audit, and reporting necessary to assure operation of the facility in a safe manner.
27 28 The regulation in paragraph (b)(4) of 10 CFR 50.68, Criticality accident requirements, states 29 that if the licensee does not credit soluble boron in the SFP criticality AOR, the keff of the SFP 30 storage racks must not exceed 0.95 at a 95 percent probability, 95 percent confidence level. If 31 the licensee does take credit for soluble boron, the keff of the SFP storage racks must not 32 exceed 0.95 at a 95 percent probability, 95 percent confidence level, if the racks are flooded 33 with borated water, and if flooded with unborated water, the keff must remain below 1.0 at a 34 95 percent probability, 95 percent confidence level.
35 36 The NRC staffs guidance for the review of TS is in Chapter 16.0, Technical Specifications, of 37 NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for 38 Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP), March 2010 (ADAMS 39 Accession No. ML100351425). As described therein, as part of the regulatory standardization 40 effort, the NRC staff has prepared Standard Technical Specifications (STS) for each of the LWR 41 nuclear designs. Accordingly, the NRC staffs review includes consideration of whether the 42 proposed changes are consistent with the applicable reference STS (i.e., the current STS), as 43 modified by NRC-approved travelers. In addition, the guidance states that comparing the 44 change to previous STS can help clarify the TS intent.
45 46 Section 9.1.1, Revision 3, of the SRP, Criticality Safety of Fresh and Spent Fuel Storage and 47 Handling, March 2007 (ADAMS Accession No. ML070570006), provides guidance regarding 48 the acceptance criteria and review procedures to ensure that the proposed changes satisfy the 49 requirements in 10 CFR 50.68.
50
1 Section 9.1.2, Revision 4, of the SRP, New and Spent Fuel Storage (ADAMS Accession 2 No. ML070550057), provides guidance regarding the acceptance criteria and review procedures 3 to ensure that the proposed changes satisfy the requirements in 10 CFR 50.68.
4 5 {NOTE: Choose applicable STS}
6 [U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Babcock and 7 Wilcox Plants, NUREG-1430, Volume 1, Specifications, and Volume 2, Bases, 8 Revision 4.0, April 2012 (ADAMS Accession Nos. ML12100A177 and ML12100A178, 9 respectively).
10 11 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Westinghouse 12 Plants, NUREG-1431, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, 13 April 2012 (ADAMS Accession Nos. ML12100A222 and ML12100A228, respectively).
14 15 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Combustion 16 Engineering Plants, NUREG-1432, Volume 1, Specifications, and Volume 2, Bases, 17 Revision 4.0, April 2012 (ADAMS Accession Nos. ML12102A165 and ML12102A169, 18 respectively).
19 20 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General 21 Electric BWR/4 Plants, NUREG-1433, Volume 1, Specifications, and Volume 2, 22 Bases, Revision 4.0, dated April 2012 (ADAMS Accession Nos. ML12104A192 and 23 ML12104A193, respectively).
24 25 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General 26 Electric BWR/6 Plants, NUREG-1434, Volume 1, Specifications, and Volume 2, 27 Bases, Revision 4.0, April 2012 (ADAMS Accession Nos. ML12104A195 and 28 ML12104A196, respectively).
29 30 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Westinghouse 31 Advanced Passive 1000 (AP1000) Plants, NUREG-2194, Revision 0, April 2016, 32 Volume 1, Specifications, and Volume 2, Bases (ADAMS Accession 33 Nos. ML16110A277 and ML16110A369, respectively).]
34 35 NUREG-1801, Revision 2, Generic Aging Lessons Learned (GALL) Report, December 2010 36 (ADAMS Accession No. ML103490041), provides guidance on what constitutes an acceptable 37 monitoring program for NAM credited for criticality control in the SFP.
38 39 The TS Section [5.5] program imposes a requirement to have a licensee-controlled program 40 that is in accordance with Nuclear Energy Institute (NEI) topical report NEI 16-03-A, Guidance 41 for Monitoring of Fixed Neutron Absorbers in Spent Fuel Pools, Revision 0, dated May 26, 2017 42 (ADAMS Accession No. ML17263A133). The NRC staff approved NEI 16-03 in an SE dated 43 March 3, 2017 (ADAMS Accession No. ML16354A486). The NEI 16-03-A topical report and the 44 NRC staffs SE for NEI 16-03 provide the technical justification for the proposed program.
45 46 [PLANT] TS Section [4, Design Features, Section 4.3, Fuel Storage,] provides limits on 47 the SFP storage racks, including limits on keff in various conditions. [LICENSEE] has credited 48 NAM in the SFP storage racks at [PLANT] to meet these requirements. There are currently 49 [no] requirements in the TS that require monitoring the condition of the NAM in the SFP. [The 50 TS requirements for monitoring the condition of the NAM in the SFP are contained in 51 TS XX.]
1 2
3.0 TECHNICAL EVALUATION
3 4 The licensee stated in Section 2.1 of the LAR that it had reviewed the NRC staffs SE of 5 TSTF-557, Revision 1, as well as the information provided in TSTF-557, Revision 1, and 6 concluded that the justifications presented in TSTF-557, Revision 1, and the SE prepared by the 7 NRC staff are applicable to [PLANT] and justify the proposed changes.
8 9 The NRC staff reviewed the proposed changes to the TS. The NRC staff reviewed the changes 10 to ensure the licensee properly accounted for any limitations or conditions placed on adoption of 11 TSTF-557. In addition, the NRC staff reviewed the proposed TS changes to ensure the TS, as 12 modified by adoption of TSTF-557, would continue to comply with the requirements of 13 10 CFR 50.36.
14 15 3.1 NEW PROGRAM FOR MONITORING NEUTRON ABSORBER 16 17 The purpose of the program is to ensure the boron-10 areal density of the neutron absorber 18 material assumed in the SFP storage rack nuclear criticality analyses remains conservative with 19 respect to the actual plant conditions.
20 21 The TS Section [5.5] program imposes a requirement to have a licensee-controlled program 22 that is in accordance with NEI 16-03-A, Guidance for Monitoring of Fixed Neutron Absorbers in 23 Spent Fuel Pools, Revision 0, May 2017. In the SE for NEI 16-03, dated March 3, 2017, the 24 NRC approved and accepted the document for referencing in licensing applications for nuclear 25 power plants. The NEI 16-03-A topical report and the NRCs SE for NEI 16-03 provide the 26 technical justification for the proposed program.
27 28 The purpose of a NAM monitoring program is to verify that the NAM installed in SFPs continues 29 to perform its safety function (i.e., criticality control) as assumed in the AOR. The guidance 30 provided in NEI 16-03 for a NAM monitoring program relies on periodic inspection, testing, 31 monitoring, and analysis of the NAM to ensure that the required subcriticality margin is 32 maintained in accordance with 10 CFR 50.68 requirements. To accomplish this purpose, the 33 guidance document states that a monitoring program must be capable of identifying 34 unanticipated changes in the absorber material and determining whether anticipated changes 35 can be verified. The guidance recommends a combination of coupon testing, in situ 36 measurement, and SFP water chemistry monitoring as a means to monitor potential changes in 37 characteristics of the NAM.
38 39 The NRC staff reviewed the proposed guidance for what constitutes an acceptable monitoring 40 program and its ability to ensure that potential degradation of SFP NAM will be detected, 41 monitored, and mitigated. In the NRCs SE for NEI 16-03, the staff determined that an 42 appropriate combination of the three methods listed above (coupon testing, in situ 43 measurement, and SFP water chemistry monitoring) as described in NEI 16-03-A, can comprise 44 an effective NAM monitoring program. Section 3.4 of the NRCs SE of NEI 16-03 states that in 45 order for a NAM program to be acceptable, a licensee must perform neutron attenuation testing 46 to verify the boron-10 areal density. Further, in Section 4.0 of the NRCs SE for NEI 16-03, the 47 NRC staff concluded that a NAM monitoring program implementing the guidance in NEI 16-03 48 provides reasonable assurance that such program will be able to detect degradation of neutron 49 absorbing material, and provides assurance that the ability of the NAM to provide the criticality 50 control relied upon in the AOR, is maintained.
51
1 Based on its review of the proposed TS changes and previous approval of NEI 16-03, the NRC 2 staff has determined that the licensees NAM monitoring program meets the provisions in 3 NEI 16-03-A. Therefore, the NRC staff finds that the ability of the NAM to perform its safety 4 function, as assumed in the AOR, is maintained, thus demonstrating compliance with the 5 subcriticality requirements of 10 CFR 50.68.
6 7 3.2 CONTINUED COMPLIANCE WITH THE REQUIREMENTS OF 10 CFR 50.36.
8 9 [PLANT] TS Section [5.5], as modified by adoption of TSTF-557, will continue to contain 10 provisions relating to procedures, recordkeeping, review and audit, and reporting necessary to 11 assure operation of the facility in a safe manner. The NRC staff determined that the TS, as 12 modified, would continue to comply with the requirements of 10 CFR 50.36. Therefore, the staff 13 determined that the proposed change is acceptable.
14 15 {NOTE: Technical reviewers and/or project manager are to assess the adequacy of any 16 variations from the approved traveler and document their acceptability. Choose the applicable 17 paragraphs based on information provided in the LAR.}
18 19 [3.3 VARIATIONS FROM TSTF-557 AND EXCEPTIONS TO NEI 16-03-A 20 21 The licensee described variations from TSTF-557 and exceptions to NEI 16-03-A in 22 Section 2.2 of the LAR. The licensee provided justification for the proposed variations 23 and exceptions. Describe why TSTF-557 is still applicable.
24 25 The NRC staff reviewed the justifications and concluded the exceptions and variations 26 from TSTF-557 are [not] acceptable because.
27 28 The NRC staff reviewed the justifications for the proposed exceptions to NEI 16-03-A and 29 concluded the exceptions are [not] acceptable because 30 31 The [PLANT] TS utilize different [numbering][and][titles] than the STS on which TSTF-557 32 was based. The NRC staff agrees these differences are editorial and do not affect the 33 applicability of TSTF-557 to the proposed LAR.
34 35 The [PLANT] design is different than the model plant assumed in the STSs, but the 36 TSTF-557 justification and the NRC staffs SE are still applicable. The NRC staff reviewed 37 the design differences and concluded differences are [not] acceptable because .]
38 39 [The [PLANT] [TS / Operating License] contain Spent Fuel Pool storage rack neutron 40 absorber material monitoring requirements approved by the NRC in [Reference].
41 [Describe, at a high level, the existing requirements and location.] [LICENSEE] proposes 42 to replace the existing requirements with the TS Administrative Controls program in 43 TSTF-557. This is acceptable as the NRC has reviewed and approved NEI 16-03-A and 44 determined it is an adequate monitoring program for SFP storage rack neutron absorber 45 material.]
46 47 3.[4] TECHNICAL EVALUATION
SUMMARY
48 49 The regulations at 10 CFR 50.36 require that TS will include items in specified categories, 50 including administrative controls. Based on its review of the proposed TS changes and previous 51 approval of NEI 16-03, the NRC staff has determined that the licensees NAM monitoring
1 program meets the applicable provisions in NEI 16-03-A. Therefore, the NRC staff finds that the 2 ability of the NAM to perform its safety function, as assumed in the AOR, is maintained, thus 3 demonstrating compliance with the subcriticality requirements of 10 CFR 50.68. The NRC staff 4 finds that the proposed new monitoring program, as adopted by [LICENSEE], allows [PLANT]
5 TS to continue to meet the requirements of 10 CFR 50.36(c)(5). Therefore, the staff determined 6 that the proposed change is acceptable.
7 8
4.0 STATE CONSULTATION
9 10 {This section is to be prepared by the plant project manager.}
11 12 In accordance with the Commissions regulations, the [Name of State] State official was notified 13 of the proposed issuance of the amendment(s) on [date]. The State official had [no]
14 comments. [If comments were provided, they should be addressed here.]
15 16
5.0 ENVIRONMENTAL CONSIDERATION
17 18 {This section is to be prepared by the plant project manager in accordance with current 19 procedures.}
20 21
6.0 CONCLUSION
22 23 {This section is to be prepared by the plant project manager.}
24 25 The Commission has concluded, based on the considerations discussed above, that: (1) there 26 is reasonable assurance that the health and safety of the public will not be endangered by 27 operation in the proposed manner, (2) there is reasonable assurance that such activities will be 28 conducted in compliance with the Commissions regulations, and (3) the issuance of the 29 amendment(s) will not be inimical to the common defense and security or to the health and 30 safety of the public.
31 32
7.0 REFERENCES
33 34 {Optional section to be prepared by the PM and primary reviewers. If a document is publicly 35 available, the ADAMS Accession No. should be listed.}
36 37 {NOTE: These are the principal contributors for the model SE of the traveler. Replace these 38 names with those who prepared the plant-specific SE.}
39 40 Principal Contributors: M. Hamm, NRR/DSS 41 M. Yoder, NRR/DLMR 42 43 Date: