ML16019A027: Difference between revisions
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The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed amendm ent in terms of regulatory requirements and the protection of public health and safety and the environment. | The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed amendm ent in terms of regulatory requirements and the protection of public health and safety and the environment. | ||
In order to make the application complete, the NRC staff requests that Duke Energy Progress, Inc. supplement the application to address the information requested in the enclosure by | In order to make the application complete, the NRC staff requests that Duke Energy Progress, Inc. supplement the application to address the information requested in the enclosure by | ||
[DATE]. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staff's request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its review activities associated with the application. If the application is subsequently accepted for review, you will R. Glover be advised of any further information needed to support the staff's detailed technical review by separate correspondence. | [DATE]. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staff's request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its review activities associated with the application. If the application is subsequently accepted for review, you will R. Glover be advised of any further information needed to support the staff's detailed technical review by separate correspondence. | ||
The information requested and associated time frame in this letter were discussed with | The information requested and associated time frame in this letter were discussed with | ||
[CONTACT] of your staff on [DATE}. | [CONTACT] of your staff on [DATE}. | ||
| Line 71: | Line 71: | ||
ML OFFICE NRR/DORL/LPLII-2/PM NRR/DORL/LPLII-2 /LA NRR/DSS/SRXB/BC NAME MBarillas BClayton CJackson DATE OFFICE NRR/DORL/LPLII-2/BC NRR/DORL/LPLII-2/PM NAME BBeasley MBarillas DATE SUPPLEMENTAL INFORMATION NEEDED AMENDMENT REQUEST DUKE ENERGY PROGRESS, INC. H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 The implementation of the previously approved method described in WCAP-16083 (within WCAP-15805), as part of the submitted license amendment request, is not consistent with the WCAP-16083 methodology limitation described in the corresponding NRC staff safety | ML OFFICE NRR/DORL/LPLII-2/PM NRR/DORL/LPLII-2 /LA NRR/DSS/SRXB/BC NAME MBarillas BClayton CJackson DATE OFFICE NRR/DORL/LPLII-2/BC NRR/DORL/LPLII-2/PM NAME BBeasley MBarillas DATE SUPPLEMENTAL INFORMATION NEEDED AMENDMENT REQUEST DUKE ENERGY PROGRESS, INC. H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 The implementation of the previously approved method described in WCAP-16083 (within WCAP-15805), as part of the submitted license amendment request, is not consistent with the WCAP-16083 methodology limitation described in the corresponding NRC staff safety | ||
evaluation. Consequently, the conclusion in the submitted license amendment request which states: "The data comparisons provided in Tables 6-9 and 6-10 show that the adjustments to the calculated spectra are relatively small and well within the assigned uncertainties for the calculated spectra, measured sensor reaction rates, and dosimetry reaction cross-sections," was found to be unjustified. Additionally, the NRC staff's acceptance review has identified a potential undiscussed bias, which may require bias correction as described in RG 1.190, Section 1.4.3, "Estimate of Fluence Calculational Bias and Uncertainty." Consequently, the NRC staff requests that the following issues be addressed in a LAR supplement: | evaluation. Consequently, the conclusion in the submitted license amendment request which states: "The data comparisons provided in Tables 6-9 and 6-10 show that the adjustments to the calculated spectra are relatively small and well within the assigned uncertainties for the calculated spectra, measured sensor reaction rates, and dosimetry reaction cross-sections," was found to be unjustified. Additionally, the NRC staff's acceptance review has identified a potential undiscussed bias, which may require bias correction as described in RG 1.190, Section 1.4.3, "Estimate of Fluence Calculational Bias and Uncertainty." Consequently, the NRC staff requests that the following issues be addressed in a LAR supplement: | ||
: 1. Considering the calculated-to-measured (C/M) data shows consistent underprediction of neutron fluence calculations when compared to measurements, provide an explanation for why the neutron fluence calculations are underpredicting fluence, and if the methodology of WCAP-16083 is found to be inappropriate as implemented as was determined by the NRC staff, then (1) revise the neutron fluence calculational methodology accordingly and/or (2) consider correcting neutron fluence calculations using the guidance in RG 1.190 if correction is found to be appropriate. | : 1. Considering the calculated-to-measured (C/M) data shows consistent underprediction of neutron fluence calculations when compared to measurements, provide an explanation for why the neutron fluence calculations are underpredicting fluence, and if the methodology of WCAP-16083 is found to be inappropriate as implemented as was determined by the NRC staff, then (1) revise the neutron fluence calculational methodology accordingly and/or (2) consider correcting neutron fluence calculations using the guidance in RG 1.190 if correction is found to be appropriate. | ||
: 2. The NRC staff noted that the unadjusted C/M summary table provided in Table 6-11 of WCAP-15805 excludes all cobalt dosimeter data and the report does not explain why. Explain why it is acceptable to remove this data. | : 2. The NRC staff noted that the unadjusted C/M summary table provided in Table 6-11 of WCAP-15805 excludes all cobalt dosimeter data and the report does not explain why. Explain why it is acceptable to remove this data. | ||
| Line 110: | Line 110: | ||
The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed amendm ent in terms of regulatory requirements and the protection of public health and safety and the environment. | The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed amendm ent in terms of regulatory requirements and the protection of public health and safety and the environment. | ||
In order to make the application complete, the NRC staff requests that Duke Energy Progress, Inc. supplement the application to address the information requested in the enclosure by | In order to make the application complete, the NRC staff requests that Duke Energy Progress, Inc. supplement the application to address the information requested in the enclosure by | ||
[DATE]. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staff's request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its review activities associated with the application. If the application is subsequently accepted for review, you will R. Glover be advised of any further information needed to support the staff's detailed technical review by separate correspondence. | [DATE]. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staff's request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its review activities associated with the application. If the application is subsequently accepted for review, you will R. Glover be advised of any further information needed to support the staff's detailed technical review by separate correspondence. | ||
The information requested and associated time frame in this letter were discussed with | The information requested and associated time frame in this letter were discussed with | ||
[CONTACT] of your staff on [DATE}. | [CONTACT] of your staff on [DATE}. | ||
| Line 128: | Line 128: | ||
ML OFFICE NRR/DORL/LPLII-2/PM NRR/DORL/LPLII-2 /LA NRR/DSS/SRXB/BC NAME MBarillas BClayton CJackson DATE OFFICE NRR/DORL/LPLII-2/BC NRR/DORL/LPLII-2/PM NAME BBeasley MBarillas DATE SUPPLEMENTAL INFORMATION NEEDED AMENDMENT REQUEST DUKE ENERGY PROGRESS, INC. H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 The implementation of the previously approved method described in WCAP-16083 (within WCAP-15805), as part of the submitted license amendment request, is not consistent with the WCAP-16083 methodology limitation described in the corresponding NRC staff safety | ML OFFICE NRR/DORL/LPLII-2/PM NRR/DORL/LPLII-2 /LA NRR/DSS/SRXB/BC NAME MBarillas BClayton CJackson DATE OFFICE NRR/DORL/LPLII-2/BC NRR/DORL/LPLII-2/PM NAME BBeasley MBarillas DATE SUPPLEMENTAL INFORMATION NEEDED AMENDMENT REQUEST DUKE ENERGY PROGRESS, INC. H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 The implementation of the previously approved method described in WCAP-16083 (within WCAP-15805), as part of the submitted license amendment request, is not consistent with the WCAP-16083 methodology limitation described in the corresponding NRC staff safety | ||
evaluation. Consequently, the conclusion in the submitted license amendment request which states: "The data comparisons provided in Tables 6-9 and 6-10 show that the adjustments to the calculated spectra are relatively small and well within the assigned uncertainties for the calculated spectra, measured sensor reaction rates, and dosimetry reaction cross-sections," was found to be unjustified. Additionally, the NRC staff's acceptance review has identified a potential undiscussed bias, which may require bias correction as described in RG 1.190, Section 1.4.3, "Estimate of Fluence Calculational Bias and Uncertainty." Consequently, the NRC staff requests that the following issues be addressed in a LAR supplement: | evaluation. Consequently, the conclusion in the submitted license amendment request which states: "The data comparisons provided in Tables 6-9 and 6-10 show that the adjustments to the calculated spectra are relatively small and well within the assigned uncertainties for the calculated spectra, measured sensor reaction rates, and dosimetry reaction cross-sections," was found to be unjustified. Additionally, the NRC staff's acceptance review has identified a potential undiscussed bias, which may require bias correction as described in RG 1.190, Section 1.4.3, "Estimate of Fluence Calculational Bias and Uncertainty." Consequently, the NRC staff requests that the following issues be addressed in a LAR supplement: | ||
: 1. Considering the calculated-to-measured (C/M) data shows consistent underprediction of neutron fluence calculations when compared to measurements, provide an explanation for why the neutron fluence calculations are underpredicting fluence, and if the methodology of WCAP-16083 is found to be inappropriate as implemented as was determined by the NRC staff, then (1) revise the neutron fluence calculational methodology accordingly and/or (2) consider correcting neutron fluence calculations using the guidance in RG 1.190 if correction is found to be appropriate. | : 1. Considering the calculated-to-measured (C/M) data shows consistent underprediction of neutron fluence calculations when compared to measurements, provide an explanation for why the neutron fluence calculations are underpredicting fluence, and if the methodology of WCAP-16083 is found to be inappropriate as implemented as was determined by the NRC staff, then (1) revise the neutron fluence calculational methodology accordingly and/or (2) consider correcting neutron fluence calculations using the guidance in RG 1.190 if correction is found to be appropriate. | ||
: 2. The NRC staff noted that the unadjusted C/M summary table provided in Table 6-11 of WCAP-15805 excludes all cobalt dosimeter data and the report does not explain why. Explain why it is acceptable to remove this data.}} | : 2. The NRC staff noted that the unadjusted C/M summary table provided in Table 6-11 of WCAP-15805 excludes all cobalt dosimeter data and the report does not explain why. Explain why it is acceptable to remove this data.}} | ||
Revision as of 10:50, 27 April 2019
| ML16019A027 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 12/08/2015 |
| From: | Kuntz R F Plant Licensing Branch III |
| To: | Connelly S R Duke Energy Progress |
| References | |
| MF7048 | |
| Download: ML16019A027 (6) | |
Text
1 NRR-PMDAPEm Resource From: Kuntz, Robert Sent: Tuesday, December 08, 2015 1:27 PM To: scott.connelly@duke-energy.com
Subject:
FW: Robinson Amendment submitted Nove mber 2, 2015 RE: Pressure/Temperature limits Attachments:Robinson PT limits amnd unacceptable with opportunity to supplement.docxI had an extra n the first attempt. If you don't mind can you confirm you received this? Thank you.
From: Kuntz, Robert Sent: Tuesday, December 08, 2015 8:43 AM To: 'scott.connnelly@duke-energy.com' Cc: Galvin, Dennis
Subject:
Robinson Amendment submitted November 2, 2015 RE: Pressure/Temperature limits Mr. Connelly, During the staff's acceptance review the staff identified additional information required for the application to be acceptable for review. The attached is a draft of the staff's information request. The staff would like to discuss the attached information this week so let me know what time will work for conducting a teleconference. If you have any questions let me know.
Robert Kuntz Sr. Project Manager NRR/DORL/LPWB (301) 415-3733
Hearing Identifier: NRR_PMDA Email Number: 2602 Mail Envelope Properties (Robert.Kuntz@nrc.gov20151208132600)
Subject:
FW: Robinson Amendment submitted November 2, 2015 RE: Pressure/Temperature limits Sent Date: 12/8/2015 1:26:38 PM Received Date: 12/8/2015 1:26:00 PM From: Kuntz, Robert Created By: Robert.Kuntz@nrc.gov Recipients: "scott.connelly@duke-energy.com" Tracking Status: None
Post Office: Files Size Date & Time MESSAGE 783 12/8/2015 1:26:00 PM Robinson PT limits amnd unacceptable with opportunity to supplement.docx 26505
Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:
Richard Michael Glover, Site Vice President H.B. Robinson Steam Electric Plant
Duke Energy 3581 West Entrance Road, RNPA01 Hartsville, SC 29550
SUBJECT:
H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 - SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED LICENSING ACTION RE: AMENDMENT REQUEST FOR TECHNICAL SPECIFICATION CHANGE TO REACTOR COOLANT SYSTEM PRESSURE AND TEMPERATURE LIMITS (CAC NO. MF7048)
Dear Mr. Glover:
By letter dated November 2, 2015, Duke Energy Progress, Inc. submitted a license amendment request for H. B. Robinson Steam Electric Plant, Unit No. 2. The proposed amendment would revise the reactor coolant system pressure and temperature limits by replacing technical specification section 3.4.3, "RCS Pressure and Temperature (P/T) Limits," figures 3.4.3-1 and 3.4.3-2, with figures that are applicable up to 50 effective full power years. The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staff's acceptance review of this amendment request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
Consistent with Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), an amendment to the license (including the technical specifications) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.34 of 10 CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.
The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed amendm ent in terms of regulatory requirements and the protection of public health and safety and the environment.
In order to make the application complete, the NRC staff requests that Duke Energy Progress, Inc. supplement the application to address the information requested in the enclosure by
[DATE]. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staff's request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its review activities associated with the application. If the application is subsequently accepted for review, you will R. Glover be advised of any further information needed to support the staff's detailed technical review by separate correspondence.
The information requested and associated time frame in this letter were discussed with
[CONTACT] of your staff on [DATE}.
If you have any questions, please contact the H. B. Robinson Steam Electric Plant, Unit No. 2 Project Manager, Martha Barillas, at (301) 415-2760.
Sincerely,
Martha Barillas, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261
Enclosure:
As stated
cc w/encl: Distribution via Listserv
ML OFFICE NRR/DORL/LPLII-2/PM NRR/DORL/LPLII-2 /LA NRR/DSS/SRXB/BC NAME MBarillas BClayton CJackson DATE OFFICE NRR/DORL/LPLII-2/BC NRR/DORL/LPLII-2/PM NAME BBeasley MBarillas DATE SUPPLEMENTAL INFORMATION NEEDED AMENDMENT REQUEST DUKE ENERGY PROGRESS, INC. H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 The implementation of the previously approved method described in WCAP-16083 (within WCAP-15805), as part of the submitted license amendment request, is not consistent with the WCAP-16083 methodology limitation described in the corresponding NRC staff safety
evaluation. Consequently, the conclusion in the submitted license amendment request which states: "The data comparisons provided in Tables 6-9 and 6-10 show that the adjustments to the calculated spectra are relatively small and well within the assigned uncertainties for the calculated spectra, measured sensor reaction rates, and dosimetry reaction cross-sections," was found to be unjustified. Additionally, the NRC staff's acceptance review has identified a potential undiscussed bias, which may require bias correction as described in RG 1.190, Section 1.4.3, "Estimate of Fluence Calculational Bias and Uncertainty." Consequently, the NRC staff requests that the following issues be addressed in a LAR supplement:
- 1. Considering the calculated-to-measured (C/M) data shows consistent underprediction of neutron fluence calculations when compared to measurements, provide an explanation for why the neutron fluence calculations are underpredicting fluence, and if the methodology of WCAP-16083 is found to be inappropriate as implemented as was determined by the NRC staff, then (1) revise the neutron fluence calculational methodology accordingly and/or (2) consider correcting neutron fluence calculations using the guidance in RG 1.190 if correction is found to be appropriate.
- 2. The NRC staff noted that the unadjusted C/M summary table provided in Table 6-11 of WCAP-15805 excludes all cobalt dosimeter data and the report does not explain why. Explain why it is acceptable to remove this data.
1 NRR-PMDAPEm Resource From: Kuntz, Robert Sent: Tuesday, December 08, 2015 1:27 PM To: scott.connelly@duke-energy.com
Subject:
FW: Robinson Amendment submitted Nove mber 2, 2015 RE: Pressure/Temperature limits Attachments:Robinson PT limits amnd unacceptable with opportunity to supplement.docxI had an extra n the first attempt. If you don't mind can you confirm you received this? Thank you.
From: Kuntz, Robert Sent: Tuesday, December 08, 2015 8:43 AM To: 'scott.connnelly@duke-energy.com' Cc: Galvin, Dennis
Subject:
Robinson Amendment submitted November 2, 2015 RE: Pressure/Temperature limits Mr. Connelly, During the staff's acceptance review the staff identified additional information required for the application to be acceptable for review. The attached is a draft of the staff's information request. The staff would like to discuss the attached information this week so let me know what time will work for conducting a teleconference. If you have any questions let me know.
Robert Kuntz Sr. Project Manager NRR/DORL/LPWB (301) 415-3733
Hearing Identifier: NRR_PMDA Email Number: 2602 Mail Envelope Properties (Robert.Kuntz@nrc.gov20151208132600)
Subject:
FW: Robinson Amendment submitted November 2, 2015 RE: Pressure/Temperature limits Sent Date: 12/8/2015 1:26:38 PM Received Date: 12/8/2015 1:26:00 PM From: Kuntz, Robert Created By: Robert.Kuntz@nrc.gov Recipients: "scott.connelly@duke-energy.com" Tracking Status: None
Post Office: Files Size Date & Time MESSAGE 783 12/8/2015 1:26:00 PM Robinson PT limits amnd unacceptable with opportunity to supplement.docx 26505
Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:
Richard Michael Glover, Site Vice President H.B. Robinson Steam Electric Plant
Duke Energy 3581 West Entrance Road, RNPA01 Hartsville, SC 29550
SUBJECT:
H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 - SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED LICENSING ACTION RE: AMENDMENT REQUEST FOR TECHNICAL SPECIFICATION CHANGE TO REACTOR COOLANT SYSTEM PRESSURE AND TEMPERATURE LIMITS (CAC NO. MF7048)
Dear Mr. Glover:
By letter dated November 2, 2015, Duke Energy Progress, Inc. submitted a license amendment request for H. B. Robinson Steam Electric Plant, Unit No. 2. The proposed amendment would revise the reactor coolant system pressure and temperature limits by replacing technical specification section 3.4.3, "RCS Pressure and Temperature (P/T) Limits," figures 3.4.3-1 and 3.4.3-2, with figures that are applicable up to 50 effective full power years. The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staff's acceptance review of this amendment request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
Consistent with Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), an amendment to the license (including the technical specifications) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.34 of 10 CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.
The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed amendm ent in terms of regulatory requirements and the protection of public health and safety and the environment.
In order to make the application complete, the NRC staff requests that Duke Energy Progress, Inc. supplement the application to address the information requested in the enclosure by
[DATE]. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staff's request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its review activities associated with the application. If the application is subsequently accepted for review, you will R. Glover be advised of any further information needed to support the staff's detailed technical review by separate correspondence.
The information requested and associated time frame in this letter were discussed with
[CONTACT] of your staff on [DATE}.
If you have any questions, please contact the H. B. Robinson Steam Electric Plant, Unit No. 2 Project Manager, Martha Barillas, at (301) 415-2760.
Sincerely,
Martha Barillas, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261
Enclosure:
As stated
cc w/encl: Distribution via Listserv
ML OFFICE NRR/DORL/LPLII-2/PM NRR/DORL/LPLII-2 /LA NRR/DSS/SRXB/BC NAME MBarillas BClayton CJackson DATE OFFICE NRR/DORL/LPLII-2/BC NRR/DORL/LPLII-2/PM NAME BBeasley MBarillas DATE SUPPLEMENTAL INFORMATION NEEDED AMENDMENT REQUEST DUKE ENERGY PROGRESS, INC. H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 The implementation of the previously approved method described in WCAP-16083 (within WCAP-15805), as part of the submitted license amendment request, is not consistent with the WCAP-16083 methodology limitation described in the corresponding NRC staff safety
evaluation. Consequently, the conclusion in the submitted license amendment request which states: "The data comparisons provided in Tables 6-9 and 6-10 show that the adjustments to the calculated spectra are relatively small and well within the assigned uncertainties for the calculated spectra, measured sensor reaction rates, and dosimetry reaction cross-sections," was found to be unjustified. Additionally, the NRC staff's acceptance review has identified a potential undiscussed bias, which may require bias correction as described in RG 1.190, Section 1.4.3, "Estimate of Fluence Calculational Bias and Uncertainty." Consequently, the NRC staff requests that the following issues be addressed in a LAR supplement:
- 1. Considering the calculated-to-measured (C/M) data shows consistent underprediction of neutron fluence calculations when compared to measurements, provide an explanation for why the neutron fluence calculations are underpredicting fluence, and if the methodology of WCAP-16083 is found to be inappropriate as implemented as was determined by the NRC staff, then (1) revise the neutron fluence calculational methodology accordingly and/or (2) consider correcting neutron fluence calculations using the guidance in RG 1.190 if correction is found to be appropriate.
- 2. The NRC staff noted that the unadjusted C/M summary table provided in Table 6-11 of WCAP-15805 excludes all cobalt dosimeter data and the report does not explain why. Explain why it is acceptable to remove this data.