ML16039A110

Dresden, Units 2 and 3 - Supplemental Information Supporting License Amendment Request Regarding Spent Fuel Storage Pool Criticality Methodology and Proposed Change to Technical Specification 4.3.1, Criticality.

ML16039A110
Person / Time
Site:	Dresden
Issue date:	02/08/2016
From:	Simpson P R Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF5734, CAC MF5735, RS-16-042
Download: ML16039A110 (5)

Text

RS-16-042 10 CFR 50.90 February 8, 2016 U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRG Docket Nos. 50-237 and 50-249

Subject:

Supplemental Information Supporting License Amendment Request Regarding Spent Fuel Storage Pool Criticality Methodology and Proposed Change to Technical Specification 4.3.1, "Criticality"

References:

1. Letter from Patrick R. Simpson (Exelon Generation

Company, LLC) to U. S. NRG, "License Amendment Request Regarding Spent Fuel Storage Pool Criticality Methodology and Proposed Change to Technical Specification 4.3.1, 'Criticality',"

dated December 30, 2014 2. Letter from Eva A. Brown (U.S. NRG) to Bryan C. Hanson (Exelon Generation

Company, LLC), "Dresden Nuclear Power Station, Units 2 and 3 -Proposed License Condition Regarding the Spent Fuel Pool Nuclear Criticality Safety Analysis Methodology (CAC Nos. MF5734 and MF5735),"

dated January 11, 2016 3. Letter from Patrick R. Simpson (Exelon Generation

Company, LLC) to U. S. NRG, "Supplemental Information Supporting License Amendment Request Regarding Spent Fuel Storage Pool Criticality Methodology and Proposed Change to Technical Specification 4.3.1, 'Criticality',"

dated October 15, 2015 In Reference 1, Exelon Generation

Company, LLC (EGG) requested an amendment to Renewed Facility Operating License Nos. DPR-19 and DPR-25 for Dresden Nuclear Power Station (DNPS), Units 2 and 3, respectively.

Specifically, EGG is utilizing a new Criticality Safety Analysis (CSA) methodology for performing the criticality safety evaluation for legacy fuel types in addition to the new ATRIUM 10XM fuel design in the spent fuel pool (SFP). In addition, EGG is proposing a change to the DNPS Technical Specification (TS) 4.3.1, "Criticality,"

in support of the new CSA. EGG proposes to add a new TS 4.3.1.1.c that will require an in-rack K-infinity limit for the fuel assemblies that are allowed to be stored in the DNPS Units 2 and 3 SFP storage racks.

February 8, 2016 U.S. Nuclear Regulatory Commission Page 2 In Reference 2, the NRG described a proposed license condition that will be necessary to ensure the Boron-1 o areal density of the Boral remains at or above its minimum credited value and the TS value of Kett < 0.95 is maintained as part of a SFP Boral coupon surveillance program.

Reference 2 requested EGG to provide a response indicating EGC's understanding and acceptance of the license condition.

EGG has reviewed the proposed license condition, and understands that the NRG plans to issue a license condition that will require the following coupon surveillance program performance objectives to be met as described in Reference

2. 1. Ensure that coupon measurements of 810 areal density are performed by a qualified laboratory;

2. Ensure that the coupons are removed for evaluation every 1 O years; 3. Ensure that should any coupon be identified as failing the minimum certified 810 areal density criterion based on coupon test results, EGG will perform in-situ testing to confirm that the minimum 810 areal density (0.02 g/cm2) is met for all panels installed in the DNPS spent fuel pools; and 4. Submit a report to the NRG within 90 days following the completion of evaluations associated with Item 3 above. The report shall include; a description of the testing results, the assessments performed, and the interim and long-term corrective actions for abnormal indications.

EGG understands that the above license condition requires that in the event a coupon is found to fail the minimum certified areal density criterion, in-situ testing of a statistically representative sample of 80RAL panels, in accordance with our program, is required to verify that the TS 4.3.1.1.a Kett requirement is met for the spent fuel storage racks. The results of this in-situ testing will be documented in a report submitted to the NRG. Based on this understanding, EGG requests that the NRG revise performance objective 3 above to read as follows:

3. Ensure that should any coupon be identified as failing the minimum certified 810 areal density criterion based on coupon test results, EGG will perform in-situ testing of a statistically representative sample of 80RAL panels to confirm that the minimum 810 areal density (0.02 g/cm2) is met for all panels installed in the DNPS spent fuel pools; and The proposed license condition discussed above impacts the regulatory commitments previously made in Attachment 9 to Reference

3. The proposed license condition will replace the need for the commitments specified in Reference

3. Therefore, a revised regulatory commitment summary is attached that supersedes the commitment summary provided in Reference 3 in its entirety.

EGG has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRG in Attachment 1 of Reference

1. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration.

In addition, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

February 8, 2016 U.S. Nuclear Regulatory Commission Page 3 Should you have any questions concerning this letter, please contact Mr. Timothy A. Byam at (630) 657-2818.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on the 8th day of February 2016. Patrick R. Simpson Manager -Licensing

Attachment:

Summary of Regulatory Commitments cc: NRC Regional Administrator, Region Ill NRC Senior Resident Inspector

-Dresden Nuclear Power Station Illinois Emergency Management Agency -Division of Nuclear Safety ATTACHMENT Summary of Regulatory Commitments The following list identifies those actions committed to by Exelon Generation

Company, LLC, (EGC) for Dresden Nuclear Power Station.

Any other actions discussed in the submittal represent intended or planned actions by EGC, are described only for information, and are not regulatory commitments.

COMMITMENT TYPE COMMITTED DATE ONE-TIME PROGRAMMATIC OR "OUTAGE" ACTION (YES/NO)

COMMITMENT (YES/NO)

None