View source for CP-201400074, License Amendment Request (LAR) 13-01 Spent Fuel Pool Criticality Analysis, Response to Request for Additional Information

{{Adams
| number = ML14063A280
| issue date = 01/16/2014
| title = License Amendment Request (LAR) 13-01 Spent Fuel Pool Criticality Analysis, Response to Request for Additional Information
| author name = Flores R
| author affiliation = Luminant Generation Co, LLC, Luminant Power
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000445, 05000446
| license number = 
| contact person = 
| case reference number = CP-201400074, LAR 13-01, TAC MF1365, TAC MF1366, TXX-1408
| document type = Letter type:CP
| page count = 3
| project = TAC:MF1365, TAC:MF1366
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:Rafael Flores Luminant Power Senior Vice President P 0 Box 1002& Chief Nuclear Officer 6322 North FM 56 rafeel.flores@Luminant.com Glen Rose, TX 76043 Luminant 254975590 C 817 559 0403 F 254 897 6652 REF: 10CFR50.90 CP-201400074 TXX-14008 January 16, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

==SUBJECT:==
COMANCHE PEAK NUCLEAR POWER PLANT (CPNPP)DOCKET NOS. 50-445 AND 50-446 LICENSE AMENDMENT REQUEST (LAR) 13-01 SPENT FUEL POOL CRITICALITY ANALYSIS, RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATION (TAC NOS. MF1365 AND MF1366)

==REFERENCE:==
: 1. Letter logged TXX-13045, dated March 28,2013, License Amendment Request (LAR) 13-01, Revision to Technical Specifications 3.7.16, "FUEL STORAGE POOL BORON CONCENTRATION," 3.7.17, "SPENT FUEL ASSEMBLY STORAGE," 4.3,"FUEL STORAGE," and 5.5 "PROGRAMS AND MANUALS" (ML13095A023)
: 2. Letter logged TXX-13109, dated July 16, 2013, "Supplemental Information supporting LAR 13-01, Spent Fuel Pool Criticality Analysis" (ML13205A056)
: 3. Letter logged TXX-13169, dated November 26,2013, regarding the CPNPP response to Requests for Additional Information for LAR 13-01, Spent Fuel Pool Criticality Analysis (ML13346A175)
: 4. Letter logged TXX-13182 dated December 17, 2013, regarding the CPNPP response to Requests for Additional Information for LAR 13-01, Spent Fuel Pool Criticality Analysis 5. Email dated January 15, 2014, from Balwant Singal of the NRC to Timothy Hope of Luminant Power, RE: Request for Additional Information 
-License Amendment Request 13-01 to Revise Technical Specifications 3.7.16, 3.7.17, 4.3 and 5.5 (TACs MF1365 and MF1366)

==Dear Sir or Madam:==
In March 2013, Luminant Generation Company LLC (Luminant Power) submitted a License Amendment Request (LAR) 13-01 (Reference 1, as supplemented by Reference 2 and the response to Requests for Additional Information in References 3 and 4) to the NRC for Facility Operating License Nos. NPF-87 and NPF-89 for Comanche Peak Nuclear Power Plant (CPNPP), Units 1 and 2, respectively.
This LAR proposes a change to the CPNPP, Units I and 2, Technical Specifications based on an updated criticality analysis methodology for the spent fuel pools.C 1JI U. S. Nuclear Regulatory Commission TXX-14008 Page 2 of 2 01/16/2014 Per Reference 5, the U.S. Nuclear Regulatory Commission (NRC) staff has requested additional information (RAI), regarding the LAR, be submitted in order to complete its review. The attachment to this letter provides Luminant Power's response to the RAIs.In accordance with 1OCFR50.91 (b), Luminant Power is providing the State of Texas with a copy of this proposed amendment.
Attachment 1 of Reference 1, Description and Assessment, which addresses the no significance hazards consideration standards set forth in 10CFR50.92, remains valid and does not require Change.This communication contains no new commitments regarding Comanche Peak Units 1 and 2.Should you have any questions, please contact Mr. J. D. Seawright at (254) 897-0140.I state under penalty of perjury that the foregoing is true and correct.Executed on January 16, 2014.Sincerely, Luminant Generation Company LLC Rafael Flores By: ThomarP. McCool Vice President, Station Support 

==Attachment:==

Comanche Peak Responses to LAR 13-01 Request for Additional Information (RAI)c -Marc L. Dapas, Region IV Balwant K. Singal, NRR Resident Inspectors, Comanche Peak Mr. Robert Free Environmental Monitoring 
& Emergency Response Manager Texas Department of State Health Services Mail Code 1986 P. 0. Box 149347 Austin, Texas 78714-9347 Attachment to TXX-14008 Page I of 1 Comanche Peak Responses to LAR 13-01 Request for Additional Information (RAI)NRC Question #1 Will there be any changes to the training curriculum for Qualified Core Performance Engineers (CPE)pertaining to the development of fuel movement plans as it relates to criticality?
If so, please describe the changes.CPNPP Response:.
Training for Qualified Core Performance Engineers will be completed prior to implementation of the Technical Specification changes, as described below.The Core Performance Engineering qualification process at CPNPP utilizes a Subject Matter Expert (SME)review to ensure personnel are knowledgeable in activities including fuel move planning and performance of Surveillance Requirement SR 3.7.17.1.
The SME Objectives for the Core Performance Monitoring qualification (required to perform or review the SR 3.7.17.1 surveillance) and the Core Performance Fuel Handling qualification (required for performing or reviewing fuel move plans) have been updated to reflect the changes to the Technical Specifications, QA software, Region I neutron absorber monitoring program, and process for performing the Surveillance.
These changes ensure that all future personnel qualified under this program will demonstrate adequate understanding of the SFP Criticality Analysis and associated limits prior to independently performing or reviewing fuel move plans.Additionally, a Training Needs Analysis was completed as part of the transition to determine the training needs for currently qualified Core Performance Engineering personnel.
This needs analysis determined that currently qualified personnel will be trained on the changes to the Technical Specifications, the supporting criticality analysis, and the implementing procedures and associated QA software.
This training is currently being developed, and will be completed for all personnel qualified to prepare or review fuel move plans prior to implementation of the Technical Specification changes.NRC Question #2 Will there be any changes to the training program for CPEs or fuel handlers due to operating experience pertaining to fuel misload accidents?
If so-,-pease describe the changes.CPNPP Response: Training for Core Performance Engineers and Fuel Handling qualified personnel has been developed as described below, and will be completed prior to implementation of the Technical Specification changes.The Operating Experience program at Comanche Peak regularly reviews industry operating experience, and applicable lessons learned are incorporated into site processes and procedures.
Since the qualification processes for fuel handling and fuel move planning activities reference current processes and procedures, the lessons learned from Operating Experience related to misload accidents are inherently included as part of the qualification process.A Training Needs Analysis was completed to determine the training needs for both Core Performance Engineers and Operations (Licensed Operators and Fuel Handling qualified personnel) based on the License Amendment Request. Through this analysis, it was determined that additional training was necessary to ensure that appropriate personnel are familiar with the revisions to the Technical Specifications, as well as the revised fuel handling procedural requirements which address the risk of a fuel misload event. This additional training focuses on the changes to the Technical Specifications, the procedure revisions as described in Enclosure I to TXX-13045 (LAR-13-01), and the increased responsibility of fuel handling personnel.
Core Performance Engineers, Licensed Operators, and Fuel Handling qualified personnel will attend this training.Operating Experience which describes an event involving multiple fresh fuel assemblies misloaded within a Spent Fuel Pool was influential on the development of the administrative controls described in Enclosure I of the License Amendment Request. This specific OE Report is included in the training material because it highlights the purpose and importance of changes to the fuel move planning controls as well as the responsibilities of fuel handling personnel.}}