ML13312A242

MF1952-RAII-SRXB-Cunana-002-2011-11-08, Request for Additional Information

ML13312A242
Person / Time
Site:	Kewaunee
Issue date:	11/07/2013
From:	Feintuch K Division of Operating Reactor Licensing
To:	Gadzala J Dominion Generation
References
MF1952
Download: ML13312A242 (4)

Text

1 NRR-PMDAPEm Resource From:Feintuch, Karl Sent: Thursday, November 07, 2013 5:50 PM To: Jack Gadzala (jack.gadzala@dom.com); Craig D Sly (Generation - 6) (craig.d.sly@dom.com)

Cc: Cunanan, Davida; Wood, Kent; Grover, Ravinder

Subject:

MF1952-RAII-SRXB-Cunana-002-2011-11-08, R equest for additional information Attachments:

MF1952-RAII-SRXB-Cunanan-002 2013-11-08.docxDRAFT REQUEST FOR ADDITIONAL INFORMATION TO DOMINION ENERGY KEWAUNEE FOR KEWAUNEE POWER STATION REGARDING THE PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS LICENSE AMENDMENT REQUEST DOCKET NO.: 50-305 TAC NO.: MF1952 By a letter dated May 29, 2013, as supplemented, (Agencywide Documents Access and Management Systems Accession Number [ADAMS] ML13156A037, and supplements, Dominion Energy Kewaunee, Inc. (DEK, the licensee), submitted a license amendm ent request (LAR) to revise the Kewaunee Power Station (KPS) Plant Technical Specifications (TSs) to support a permanently defueled license and technical specifications consistent with the permanent cessation of reactor operation.

The NRC staff has reviewed the information the licensee provided and determined that additional information isneeded in order to complete the review. A request for additional information (RAI) is attached. In this case the cognizant Technical Branch is SRXB (Reactor Systems). The cognizant Reviewer is Davida Cunanan.

Please review the RAI item (RAII) for clarity and contact Karl Feintuch, USNRC, 301-415-3079, if a clarification conference call is needed and to confirm an expected response date, typically desired for 30 days from receipt, as confirmed. Upon confirmation of clarity and schedule the RAII is considered to transition from draft to firm.

Hearing Identifier: NRR_PMDA Email Number: 910 Mail Envelope Properties (Karl.Feintuch@nrc.gov20131107174900)

Subject:

MF1952-RAII-SRXB-Cunana-002-2011-11-08, Request for additional information Sent Date: 11/7/2013 5:49:47 PM Received Date: 11/7/2013 5:49:00 PM From: Feintuch, Karl Created By: Karl.Feintuch@nrc.gov Recipients: "Cunanan, Davida" <Davida.Cunanan@nrc.gov>

Tracking Status: None "Wood, Kent" <Kent.Wood@nrc.gov>

Tracking Status: None "Grover, Ravinder" <Ravinder.Grover@nrc.gov> Tracking Status: None "Jack Gadzala (jack.gadzala@dom.com)" <jack.gadzala@dom.com> Tracking Status: None "Craig D Sly (Generation - 6) (craig.d.sly@dom.com)" <craig.d.sly@dom.com> Tracking Status: None Post Office: Files Size Date & Time MESSAGE 1408 11/7/2013 5:49:00 PM MF1952-RAII-SRXB-Cunanan-002 2013-11-08.docx 23067 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

DRAFT REQUEST FOR ADDITIONAL INFORMATION TO DOMINION ENERGY KEWAUNEE FOR KEWAUNEE POWER STATION REGARDING THE PERMANENTLY DEFUELED LICENSE AND TECHNICAL SPECIFICATIONS LICENSE AMENDMENT REQUEST DOCKET NO.: 50-305 TAC NO.: MF1952 By a letter dated May 29, 2013, as supplemented, (Agencywide Documents Access and Management Systems Accession Number [ADAMS] ML13156A037, and supplements, Dominion Energy Kewaunee, Inc. (DEK, the licensee), submitted a license amendment request (LAR) to revise the Kewaunee Power Station (KPS) Plant Technical Specifications (TSs) to support a permanently defueled license and technical specifications consistent with the permanent cessation of reactor operation.

The NRC staff has reviewed the information the licensee provided and determined that additional information is needed in order to complete the review. A request for additional information (RAI) follows. In this case the cognizant Technical Branch is SRXB (Reactor Systems). The cognizant Reviewer is Davida Cunanan.

Please review the RAI item (RAII) for clarity and contact Karl Feintuch, USNRC, 301-415-3079, if a clarification conference call is needed and to confirm an expected response date, typically desired for 30 days from receipt, as confirmed. Upon confirmation of clarity and schedule the RAII is considered to transition from draft to firm.

MF1952-RAII-SRXB-Cunana-002-2011-11-08 RAI-2 In the spent fuel pool (SFP), the spent fuel stored in the racks must comply with the regulations to remain subcritical. In the case of Kewanee, they are licensed under 10 CFR 50.68 "Criticality Accident Requirements." This regulation states that:

If no credit for soluble boron is taken, the k-effective of the spent fuel storage racks loaded with fuel of the maximum fuel assembly reactivity must not exceed 0.95, at a 95 percent probability, 95 percent confidence level, if flooded with unborated water.

To demonstrate compliance with the regulation, the licensee has performed a nuclear criticality safety (NCS) analysis of record (AOR). In this NCS AOR, Kewanee has credited neutron absorbers in the analysis to help maintain subcriticality. In order to ensure that the neutron absorbers will remain within the assumptions used in the NCS AOR, a Surveillance Program to identify and monitor any degradation is in place or is planned to be implemented in the near future. These programs will confirm that the materials will perform as designed for in the NCS AOR.

The staff questions the amount of information described in Kewanee's proposed Technical Specifications in regard to the neutron absorbing materials and it's Surveillance Programs. In particular:

1. Neutron absorbing materials need to be monitored and degradation mitigated in the SFP to ensure that the assumptions in the criticality analysis of record and thereby the TS 4.3.1 are not challenged. Since the materials are integral to the compliance of the TS 4.3.1 and the regulations, the areal density of the neutron absorbers and the details of the neutron absorber surveillance programs should be reflected in the TS.

Please describe how this will be achieved.

Note: In justification for having a neutron absorbers and its surveillance programs in TS, please see 10 CFR 50.36 (c)(2)(ii)(B), where it states:

Criterion 2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Furthermore 10 CFR 50.36(c)(2)(ii)(C) states:

Criterion 3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that wither assumes the failure of or presents a challenge to the integrity of a fission product barrier.